Privacy Policy

GAME ORCAS Ltd., its partners, parent companies, subsidiaries, licensees, licensors and affiliates (collectively, the “Company”, “we” or “us”), develop, publish, market and commercialize a variety of games for use on various platforms, including mobile devices (our “Applications”) through which we offer relating game play and social gaming services, including the ability to make purchases through the Applications.

We respects your concerns about privacy and value our relationship with you. This Policy describes the types of information we collect through the Site, how that information may be used and/or with whom it may be shared; and how you can reach us to update your contact information, access and control the use of the information we collect in connection with our marketing communications and activities or get answers to questions you may have about our privacy practices on the Site.

Please read this Policy carefully, because by using the Site you acknowledge that you understand and agree to the terms of this Policy.

1. What is Personal Information?

As used herein, the term "Personal Information" means information that specifically identifies an individual (such as a name, e-mail address), or information about that individual that is directly linked to personally identifiable information. Personal Information does not include "aggregate information," which is data we collect about the use of the Site or about a group or category of services or users from which individual identities or other personal information has been removed. Personal Information also does not include Usage Information (as defined below) or Device Identifier (as defined below) that is not connected to Personal Information. This Policy in no way restricts or limits our collection and use of aggregate or Usage Information that is not connected to Personal Information.

2. Information Collected on Our Site

Information You Provide To Us

You may choose to provide Personal Information through the Site. For example, the Company may collect Personal Information when you request information, submit comments, participate in some other feature of the Site, or otherwise communicate or interact with us. If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as Personal Information. If you do not want your Personal Information collected, please do not submit it.

Information Collected by Automated Means

Whenever you visit or interact with the Site, the Company, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Site is accessed and used ("Usage Information"). Usage Information may include, in part, browser type, operating system, the page served, the time, how many users visited the Site, and the preceding page views. This statistical data provides us with information about the use of the Site, such as how many visitors visit the Site, how long they stay on that page, and which hyperlinks, if any, they "click" on. This information helps us to keep the Site fresh and interesting to our visitors and to tailor content to a visitor’s interests. Usage Information is generally non-identifying, but if the Company associates it with you as a specific and identifiable person, the Company treats it as Personal Information. The technologies used on the Site to collect Usage Information, including Device Identifiers, may include, without limitation:

Information We Receive from Third Parties

We may receive information about you from third parties. If you access the Services through a third-party connection or log-in, we may also collect your user ID and/or username associated with that third-party service, and any information you have made public in connection with that service or which the third party shares with partner services. In addition, we may receive information about you if other users of a third party web site give us access to their profiles and you are one of their "connections" or information about you is otherwise accessible through your "connections" webpage, profile page, or similar page on a social networking or other third party website or interactive service. The collection and use of this information is pursuant to such third party’s information collection practices, which are typically outlined in a policy like this one, provided on the third party’s website or application. We also may supplement the information we collect about you through the Site with other information from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the information we receive from these third parties with information we collect through the Site. In those cases, we will apply this Policy to any Personal Information received, unless we have disclosed otherwise.

3. How We Use the Information Collected

The main use of the information we collect and store is to provide a better gaming experience, but there are other uses as well. The uses for which we collect and store your information include:

4. What Personal Information do we share with third parties?

We will not share the personal information we collect from you through the Site with third parties, except as described in this Policy or on the Site. We may share non-Personal Information, such as aggregate user statistics, demographic information, and Usage Information with third parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Policy, and in the following circumstances:

With your consent, we may share your information with third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy.

Third-Party Service Providers. We will share your information with third-party companies to perform services on our behalf, like processing payments, analyzing data, optimizing game play, e-mail delivery, hosting services, customer service and to help us in our marketing efforts, including managing and delivering contextual and tailored advertisements. We contractually require these third-party service providers to maintain the confidentiality of the information we share with them, and we contractually require them not use your information for anything other than to provide services on our behalf.

Legal Disclosure. We may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Service or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Site or the public.

5. Legal Basis for Data Processing

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites.In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites.

6.International Transfer of Personal Data

Our business may require us to transfer your Personal Data to countries outside of the European Economic Area (EEA, including to countries such as the People’s Republic of China or Singapore. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard contractual clauses. A copy of those clauses can be obtained by contacting our Help Center.

7. How We Protect Personal Information

We maintain certain administrative, technical and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Site and provide us with your information at your own risk.

8.Your Access and Rights

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.

Where the use of your information is based on consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Requests should be submitted by contacting us through customerservice@gameorcass.com.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.

We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

9. Our Policies Concerning Children

The Site is not directed to children under 13. We do not knowingly collect personally identifiable information from anyone under 13 years of age. If we determine upon collection that a use is under this age, we will not use or maintain his/her Personal Information without the parent/guardian consent.

10. What Choices Do You Have Regarding Our Use of Your Personal Information?

We provide a variety of ways for you to control the personal information we hold about you, including choices about how we use that information. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law.

In some jurisdictions, you have the right to access, receive a copy of, correct, and delete your personal information. If you reside in one of these jurisdictions, and you wish to access, receive a copy of, correct, or delete personal information about you that we hold, you may make your request by emailing customerservice@gameorcass.com. We may need you to provide some personal information so that we may verify your request and locate your personal information to fulfill your request.

Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have previously allowed us to access your precise geolocation data or receive push notifications through your device, you can stop making precise geolocation available to us or receiving push notifications by visiting your mobile device's settings for the relevant Application or in some cases, through the Application itself.

11. How to Contact Us

If you have any questions or comments about this Policy, please contact us at customerservice@gameorcass.com.