EU Privacy Policy

Table of Contents

Introduction

Third Party Sites

Our Policy Concerning Children

The Types of Information We May Collect

Our Use of Cookies

How We Use the Information We Collect

Lawful Basis for Processing Your Personal Data

Sharing Your Personal Data

How Do We Keep Your Information Secure

Your Legal Rights

Data Retention

Modifications to This Policy

International Transfers

Questions and Contact Details

Introduction

Ember Entertainment, Inc., a Delaware corporation, (“Ember,” “we,” or “us”) respects your rights and our obligations regarding your privacy and personal data (as defined in the GDPR, defined below) and we provide this Privacy Policy (this “ Privacy Policy”) to help you understand how we collect, use, share, store, and disclose information we obtain from or about you when you use (a) any websites we operate or that are operated on our behalf and on which this Privacy Policy appears, including all websites located at ember-entertainment.com URLs (collectively, the “Websites”); and/or (b) the services we provide and which are accessible on or through the Websites and/or other third party platforms, including without limitation games, community forums, and blogs (all of which are collectively referred to as the “Services”, provided, however, that any services we provide subject to a different privacy policy shall not be considered part of the “Services”).

 

This Policy applies regardless of the means by which we collect your personal data. For example, this Privacy Policy would apply to personal data collected automatically by cookies and other tracking mechanisms when you use the Websites or Services, and to personal data you send us via email, over the phone or via any other method.

 

For the purposes of the General Data Protection Regulation of the European Union (the “GDPR”), Ember Entertainment, Inc., a Delaware corporation, is the data controller (as defined in the GDPR) with respect to personal data processed hereunder, except where indicated otherwise. Ember’s contact details are included in the section “Questions and Contact Details” below. This Privacy Policy only applies to you if you reside in the European Economic Area. If you reside elsewhere your use of the Sites and Services is subject to our global privacy policy which can be found at http://ember-entertainment.com/privacy-policy.

 

THIS IS A LEGALLY BINDING AGREEMENT BETWEEN YOU AND EMBER, AND BY USING THE WEBSITE AND SERVICES, YOU AGREE TO THE TERMS OF THIS AGREEMENT. You should review this Policy in conjunction with our Terms of Service available on our Website, and any other agreement provided by us that governs your use of the Websites and Services. You should not use the Websites and/or Services if you do not agree with any of the foregoing. Terms not otherwise defined herein shall the same meaning as any definition set forth in the Terms of Service.

 

Third Party Sites

The Websites and/or Services may contain links to other websites that are owned or operated by third parties (referred to in our Terms of Service as “Linked Sites”). When you click on any link for a Linked Site and/or visit a Linked Site’s website, you should be aware that you are leaving an Ember Site, and this Policy does not apply to any such Linked Sites. Additionally, if you use our Services on or through a third party platform, including via any wireless devices (like your mobile phone or tablet), your personal data may also be processed by and subject to the privacy policies and terms of service of the third party platform. We do not control and are not responsible for the terms of service, privacy policies and/or practices of any Linked Sites or any third party platform you may use to access the Websites and/or Services, and you should review the policies and agreements of such Linked Sites and/or third party platforms carefully.

 

Our Policy Concerning Children

The Websites and Services are not intended for children under the age of 16 and we do not knowingly collect any personal information from such children. Children under the age of 16 should not use or attempt to use our Websites or Services, and if you are under 16, please do not attempt to use our Website or Services or send any information about yourself to Ember. In the event that we learn that we have inadvertently gathered personal data from a child under the age of 16, we will take reasonable measures to erase such information from our records. Parents who believe that Ember might have any information from or about a child under 16, may submit a request to privacypolicy@ember-entertainment.com and request that the information be removed.

 

The Types of Information We May Collect

Ember may collect different information from or about you depending upon the manner in which you use the Websites or Services. The following examples are provided to help you better understand the information we may collect through your use of and/or interaction with the Websites and/or Services:

 

Information Received Through Your Third Party Platform Account

When you use or connect to an Ember Website or Service on or through a third party platform, such as Facebook or another social networking site, (including using a third party platform account to sign into an Ember Website or Service), you allow us to access and/or collect certain information from your third party platform account as permitted by the terms of the agreement and your privacy settings with the third party platform. The information you allow us to access and collect varies depending on the Ember Service you use as well as the terms of the third party platform and your privacy settings thereon. By way of example only, Ember may access and/or collect some or all of the following information from your third party platform account: your full name as provided to the third party platform, your profile picture or its URL, your user ID number, which is linked to publicly available information such as name and profile photo, the user ID numbers for your friends that are also connected to our game(s), the login e-mail you provided to the third party platform when you registered, your physical location and that of your access devices, including any wireless device (collectively, “Third Party Platform Information”).

 

By using an Ember Service on or through a third party platform, you are authorizing Ember to collect, store, and use your Third Party Platform Information in accordance with this Privacy Policy and as allowed by the terms of the third party platform and your privacy settings with the third party platform. You may choose to not allow the third party platform to provide us with certain information about you, but you might not be able to use certain features of our Websites and/or Services if you do so. You can also avoid having a third party platform share information with Ember by registering for the relevant Website or Service directly with Ember.

 

When you use an Ember Service we may assign you a unique identifying number (“ID number”) which is not publicly displayed to other Ember users. Additionally, you may be able to select a user name and/or in-game character name (collectively, “User Name”). Please note, your User Name will be publicly viewable by others who have access to the Websites and/or Services, and, in some instances, may be viewable to others outside of Ember through Internet searches and/or indexing. We recommend you do not use your real name or other information that may be used to personally identify you as part of your User Name as this information may be used to make unwanted contact with you or for other purposes by third parties. We are not responsible for your User Name and/or the manner in which it may be used by third parties.

 

Information Received Through Your Wireless Device

If you use an Ember Service on or through a wireless device, we may, in accordance with the terms of any applicable agreement with the wireless device carrier (and as allowed by your privacy settings) collect certain information such as your unique device identifier (a number automatically assigned to your mobile or wireless device), device type, and information you choose to provide or share through your wireless device, such as e-mail address.

 

We may send push notifications to your mobile device to provide game updates and other relevant messages. You can manage push notifications from the “options” or “settings” page within the mobile application. You also may be able to manage them from your device’s settings page for the mobile application.

 

We do not ask you for, access or track any precise location based information from your mobile device at any time while downloading or using the Sites and/or Services. Any location information we do obtain is not used to inform any advertising or marketing material targeted to you.

 

Information You Provide to Us Directly

When you use any of the Websites or Services (including through a third party platform) we will collect any information you provide to us directly such as registration information we request in connection with your use of certain Websites or Services or portions thereof (for example, name, age, birthday, email address and password) and any additional profile information you choose to provide. You should exercise care and caution in adding any additional profile information as profile information will be publicly viewable to others and may in some instances be indexed by search engines and viewable outside of the Ember Websites and/or Services. Your profile information may be used by third parties in unwanted ways, and Ember is not responsible for information you supply in your Profile and/or the manner in which it is used by others.

 

Public Posting

Some of the Ember Websites or Services may allow you to interact with other users and/or post, share, communicate with, or otherwise transmit content publicly, such as by participating in player forums, message boards, news feeds, status updates, posting public comments to users’ profiles, sending messages or invitations to other users, chatting with other users, posting photos, and/or posting comments to a wall (collectively “Public Posting”). We may collect and store archives of such Public Postings on Ember’s servers, and all Public Postings are subject to this Privacy Policy and may be used or disclosed pursuant to the terms of this Privacy Policy and the Terms of Service, including but not limited to protecting the safety and well-being of members of the public, minors, Ember users, our employees, and our Websites or Services.

Keep in mind that your Public Posting will be visible to anyone who has access to the Websites or Services and may in some instances be viewable outside of Ember as such Public Postings may, in certain instances, show up in Internet searches and/or be indexed by search engines. Using certain tools, it may be possible for you or third parties to copy, cut, and/or post your Public Posting or other information to different locations (including to websites not owned/operated by Ember). This may result in the disclosure of private information on third party websites—for which Ember is not responsible—and, in some cases, may subject you to liability for information posted by or about you. Therefore, you should exercise caution in all Public Postings, and we recommend you do not provide personal information that may be used to identify and/or contact you in a Pubic Posting. To request removal of your Public Postings, contact us. In some cases, we may not be able to remove your Public Postings, in which case we will let you know if we are unable to do so and why.

 

On some Ember Websites and Services, your User Name as well as your Profile Information (including any third party platform profile picture) may be displayed in conjunction with your Public Posting. Thus, those accessing this information may be able to identify you, including by using other available sources of information, such as your related third party platform account or information on other websites.

 

Payment Information

If you purchase any products or services through our Websites or Services, such as in game Virtual Currency (as defined in the Terms of Service), Site Items (as defined in the Terms of Service) or goods, we may collect certain information regarding your purchase (such as your name or other identifier and purchase details) as necessary to process your order, and you will be required to provide certain payment and billing information directly to our payment processing partners, such as but not limited to your name, credit card information, billing address, and zip code. We do not directly access, store or collect your credit card information, and we will not use your payment information except as needed to fulfill your purchase and/or communicate with you regarding your transaction.

 

Communications, Support Requests, Potential Abuse

If you contact us for assistance or to report a problem, concern, potential abuse or other issue regarding the Websites, Services or a user, we may collect and store your contact information, communication, and/or other information about you, including but not limited to your name, e-mail address, User Name, ID number, location, game play or activity, and we reserve the right to conduct further research and obtain further information as necessary. We will use the information to respond to you, research your request/communication, and in accordance with provisions of this Privacy Policy. The same applies where another user complains about potential abuse by you.

 

Sweepstakes, Promotions, and Surveys

From time to time, we may ask you to complete a survey, participate in our loyalty programs and/or offer you the opportunity to participate in promotions. If you choose to participate in a promotion, we will collect and store the information you provide in connection with your participation in the Promotion, such as your name, ID number, e-mail address, date of birth, phone number and whatever other information you provide, and we will use and/or disclose that information in accordance with this Privacy Policy unless stated otherwise, such as in the official rules (or other guidelines) of the promotion or as stated in another privacy policy that may govern the promotion. All of our promotions are intended for people who are the age of majority in their respective state, province, or country unless otherwise expressly stated. In all cases where required, promotions will have official rules or guidelines that outline what information is being collected or users will be directed to the most recent version of this Privacy Policy.

 

In some cases, the information collected will be used only to administer the promotion; in other cases, the information collected will be used for Ember’s or sponsor’s marketing purposes. Your information may be used to contact you for winner notification, prize delivery confirmation or other related purposes and/or in accordance with this Privacy Policy. Your entry in the promotion may also result in your being added to our mailing lists as well as those of our promotional partners associated with the promotion. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information on our Website, such as on a winner’s page, in the event you win a promotion.

 

Technical & Usage Information We Collect Through Automated Means

When you access the Websites or Services, including playing any of our games, our servers automatically record, and we automatically collect, certain information by automated means. This information may include without limitation: (a) technical information about your computer or wireless device, such as your IP address, operating system type, device ID, browser, domain and other systems information as further explained in this Privacy Policy; and (b) usage statistics about your interaction with the Websites and/or Services, including games accessed, game score, pages visited, use of Site Items and Virtual Currency, information about your game play and interaction with other users, portions of the Websites or Services used/visited, and other information regarding your use of the Websites and Services.

 

This technical information and usage data, some of which may be linked to your ID number, is collected through the use of server log files and tracking technologies, including: (i) cookies, which are small files that websites send to your computer or wireless device to uniquely identify your browser or wireless device or to store information in your browser settings; and (ii) web beacons, which are small files that allow us to measure the actions of visitors to the Websites or Services. For more detailed information regarding how we use cookies and other technology, please review the additional information in this Policy under the Section entitled “Our Use of Cookies

 

Our servers do not record or recognize names or e-mail addresses of the user, unless the user registers for an account or provides such information to us in some other way, such as via a transaction or Submission (as  defined in our Terms of Service). The technical information we obtain may be used and shared for a number of purposes, including to improve the quality of our Sites and Services; evaluate the effectiveness and popularity of certain Sites and Services; track user’s movements and playing habits; analyze broad demographic trends; verify compliance with our product license agreements; and improve user experience; and as further set forth in this Privacy Policy. We may use and share with third parties Technical Information (defined below) or aggregated Technical Information to show general demographic and preference information among Ember users. Our use and disclosure of anonymous information including aggregated Technical Information is not subject to any of the restrictions in this Privacy Policy.

 

Our Use of Cookies

Like many websites Ember (and/or service providers acting on our behalf as described on Exhibit A to this Privacy Policy) uses server log files and automated data collection tools, such as cookies, tags, scripts and web beacons (collectively, “Data Collection Tools”) when you access or visit our Websites and Services. These Data Collection Tools automatically track and collect certain technical information that your browser sends to our Websites such as your IP addresses, device IDs, browser types, browser language, referring and exit pages, URLs, platform type, the number of clicks, domain names, landing pages, clickstream data, pages viewed and the order of those pages, the amount of time spent on particular pages, game information and the date and time of activity on our Webites or Services, and other similar information (collectively, “Technical Information”). In some cases, we will associate this Technical Information with your ID number for our  use or with your other personal data. By using our Websites and/or Services, you consent to our use of cookies, web beacons and Data Collection Tools.

 

We use cookies for a variety of reasons, including to: (i) analyze the usage of our Sites and Services; (ii) provide a more personalized experience; (iii) manage advertising; (iv) allow you to more easily login to our Sites and Services; (iv) help make your visit to our Websites and/or use of our Services more efficient and more valuable by providing you with a customized experience and recognizing you when you return.

 

We may also employ web beacons or other technology for a variety of reasons such as: (i) allowing us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation.

 

You can set your web browser to warn you about attempts to place cookies on your computer, limit the type of cookies you allow or refuse cookies all together; however, you may not be able to use some or all of the features of the Websites and/or Services if you refuse/disable cookies.

 

Please note that third parties partners/providers, such as companies delivering advertisements in our games or on the Websites and/or Services (which are listed in Exhibit A or otherwise referred to in this Privacy Policy), may also use cookies or other tracking technologies, and those practices and providers are subject to their own policies. Third parties with whom we partner to provide certain features on our site use Local Storage Objects (LSOs) such as Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here:

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

 

Session Cookies

We use a session cookie to remember your log-in for you and process your purchases of Site Items. These we deem strictly necessary to the working of the Websites. If these are disabled, then various functionalities on the site will be broken.

 

Analytics Cookies

 

Google Analytics – we use this to understand how the site is being used in order to improve user experience. You can find out more about Google’s position on privacy as regards its analytics service at:

http://www.google.co.uk/intl/en/analytics/privacyoverview.html 

 

Cookies used:

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GamesAnalytics – GamesAnalytics tracks and records certain information about you on behalf of Ember so that we may improve your gameplay experience and for analytics and marketing purposes. You can review the GamesAnalytics Privacy Policy here: https://gameanalytics.com/privacy

 

IronSource – we partner with IronSource to display advertisements through our Websites and Services and doing so may involve tracking and recording certain information about you. If you reside in the European Economic Area you will be displayed generic advertisements that have not been personalized for you according to your personal data. You can review the IronSource Privacy Policy here: https://developers.ironsrc.com/ironsource-mobile/ios/ironsource-mobile-privacy-policy/

 

AppsFlyer – we partner with AppsFlyer to track and analyze the characteristics of our end users. Information collected by AppsFlyer includes (i) unique identifiers and technical data, such as IP address, user agent, identifier for advertisers (an identification number assigned to users to analyze their characteristics) or Android ID (for Android users only); (ii) technical data regarding your operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. You can review the AppsFlyer Privacy Policy here: https://www.appsflyer.com/privacy-policy/

 

How We Use the Information We Collect

Ember may use the information we collect through your use of the Websites and Services for a variety of purposes, primarily related to providing and improving the quality of our Websites and Services. For example, we may use the information we collect in the following ways: (a) providing, administering, and facilitating your use of the Websites and Services, including the display of customized content and/or targeted advertising, without which Ember would be unable to offer free gameplay; (b) notifying you of products, new products, services, features, promotions, enhancements, and updates, including in-game updates, loyalty and rewards programs, and updates to the Websites, Services, Terms of Service, and Privacy Policy; (c) marketing our products and/or services to you, including sending you offers, promotions information, newsletters, e-mail campaigns, and communications regarding new, improved or existing products, contests and/or sweepstakes and asking you to participate in surveys; (d) resolving site problems; handling or responding to customer support questions and issues; (e) processing or fulfilling your request(s) and/or order(s) for games, products, services, information or features, such as Site Items and Virtual Currency; (f) enabling user-to-user communication and interaction and soliciting input and feedback to improve user experience; (g) managing your account preferences, establishing your Profile and Registration Information; (h) connecting you with your friends and/or contacts that are using the Websites and/or Services; (i) monitoring the technical functioning of the Websites, Services, and network; (j) developing new and/or improved games, products, services or offerings; (k) to create, review, analyze and share Aggregate Information; (l) identifying, researching, and protecting against any actual, potential or threatened misuse, unauthorized use, or unwanted use of any of the Websites or Services; (m) analyzing trends and user traffic; (n) resolving disputes; (o) communicating with you; (p) as we, in our sole discretion, otherwise determine to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Websites and Services; or (q) in any other manner that is compatible with the foregoing purposes.

 

Lawful Basis for Processing Your Personal Data

We will only use your personal data as permissible by law. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override our interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than (i) in relation to the use of non-essential cookies, which are mainly used for profiling purposes in connection with marketing and analytics activities; and (ii) in relation to sending direct marketing communications to you via direct mail, email, text message or otherwise, where we do not have an existing business relationship or other legitimate interest in doing so. If we do rely on consent, you have the right to withdraw consent to marketing activity at any time by contacting us in the manner set forth in this Privacy Policy. If we do not rely on consent, you have the right to object to our processing of your personal data in any case, again, by contacting us. If you object to certain types of processing you may no longer be able to use all or part of the Websites and Services.

Where we rely on legitimate interests as our lawful basis for processing your personal data, the legitimate interest is typically one of the following: to operate Websites and Services and our business generally, to serve advertisements which help fund the Websites and Services, to improve our Websites and Services and maintain their relevance and attractiveness to users, to perform transactions with you and related third parties, to maintain accurate records, to study how our Websites and Services are used, to ensure the security and intended operation of our Websites and Services, to prevent fraud, to promote our Websites and Services and to inform our marketing strategy and to communicate with you.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

 

Sharing Your Personal Data

We will only share your information (including personal data) with the third parties listed on Exhibit A (as updated from time to time) or under the following circumstances:

 

Safety, Security, Cooperation With Law Enforcement, & Compliance With Legal Obligations 

We may disclose your information to third parties, including your personal data, if we, in our sole discretion, have a good faith belief that disclosure is (a) permitted or required by law; (b) requested in connection with or relevant to a judicial, governmental or legal inquiry, investigation, order, or proceeding; (c) required or reasonably necessary pursuant to a valid subpoena, warrant or other legally valid inquiry or request; (d) reasonably necessary to enforce our Terms of Service, this Privacy Policy, or any other legal agreements; (e) required to detect, prevent, or otherwise address fraud, abuse, misuse, potential violations of law (or rule/regulation), and/or security or technical issues; or (f) required or reasonably necessary to protect against imminent harm to the rights, property or safety of Ember, our users, employees, any minors, members of the public and/or our Websites and Services. We may also disclose information about you to our auditors or legal advisors in conjunction with evaluating our disclosure obligations and/or rights under this Privacy Policy.

 

Employees, Third Party Service Providers, Contractors or Agents 

We may share your information with our employees, the third party companies that perform services on our behalf described on Exhibit A, as amended from time to time, including payment processing, order fulfillment, data analysis, marketing services, e-mail campaigns, hosting services, and customer service. While providing the services for us, these companies may access your personal information, and are required to use it solely as directed by us.

 

Business Transfers, Sales or Mergers or Divestitures

In the event that Ember undergoes a business transition, such as a merger, acquisition, corporate divestiture or dissolution (including bankruptcy), or a sale of all or a portion of its assets, including in connection with the sale or other transfer of a game, we may share, disclose or transfer all of your information, including personal data, to the successor organization in such transition.

 

Promotions 

We may share your information in connection with any promotion you enter on or through the Websites, as necessary to administer, market, sponsor, or fulfill the promotion or as required by applicable laws, rules or regulations (for example, to provide winners’ lists or make required filings as appropriate) or in accordance with the applicable official rules of the promotion you enter.

 

With Your Permission

Additionally, if you opt-in or otherwise agree to have your information shared with a third party for marketing or analytics purposes, including by agreeing to the use of cookies or other tracking devices, we will share your information with the third party (or third parties) in which case the third party’s use of your information is subject to the third party’s own privacy policy to the extent the relevant third party is the Data Controller with regard to the information it collects.

 

Advertising of Third Party Products/Services

We may use and share with third party advertisers (and other third parties) certain Technical Information (which may include personal data) and/or anonymized information to show general demographic and preference information among Ember users. We may also allow advertisers to collect Technical Information and other personal data, which they may share with us, through the use of tracking technologies like cookies and web beacons as described earlier in this Privacy Policy. The information collected may be used to to undertake web analytics (i.e. to analyze traffic and other end user activity to improve your experience) and for general marketing purposes. Users residing in the European Economic Area will only be served generic advertisements and not personalized advertisements.

 

Social Media Features 

Our Web site includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing them.

 

Offer Walls 

Ember games or their purchase pages may display an “offer wall” that may be hosted by a third party offer wall provider. The offer wall allows third party advertisers to provide virtual currency to users in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These offers are not controlled by or made by Ember. These offers may be displayed to you based on certain technical information, such as your geographic area or anonymous demographic information. After clicking on one of these advertisements, you will no longer be on a site hosted by Ember or a partnering Third Party Platform. To properly credit user accounts and to prevent fraud, a unique identifier will be shared with the offer wall provider. This identifier is used to ensure proper crediting of your account, prevent fraud or duplicate offers and to resolve any customer service inquiries that may arise. Once you complete an offer, you may then be returned to an Ember Website or Service.

 

How Do We Keep Your Information Secure?

Ember takes appropriate technical and organizational security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, personal data that you share and we collect and store. These security measures may include practices such as keeping your sensitive data on a secured server behind a firewall, transmitting sensitive information (such as a credit card number) entered on our site or mobile application using secure socket layer technology (SSL), internal reviews of our data collection practices and platforms, as well as physical security measures to guard against unauthorized access to systems where we store your information. Unfortunately, however, no security system can be 100% secured, and we cannot guarantee that communications between you and Ember, the Websites or Services, or any information provided to us in connection with the information we collect through the Websites or Services will be free from unauthorized access by third parties. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Your password is an important component of our security system. As such, it is your responsibility to protect it. Do not share your password with any third parties. If your password has been compromised for any reason, you should change it immediately and follow the notification procedures set forth in Section 6 of our Terms of Service. 

 

Your Legal Rights

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, to request your information in a structured, electronic format, the right to have your personal data rectified if it is incorrect, the right to withdraw your consent to processing of your personal data (where the consent is the lawful basis for such processing) and the right to lodge a complaint with a supervisory authority, which may be the Data Protection Authority in the country where you reside.

 

You can exercise some of the choices (including deleting an account) by accessing your account or the relevant Website or Service and using settings available within your account or the relevant Website or Service. If you play multiple Ember games we will require that you make a separate request for each game account. Otherwise, you can contact us to exercise your rights using the contact information displayed at the end of this Privacy Policy.

To manage the information Ember receives about you from a third party platform or wireless device, please follow the instructions provided by the third party platform or wireless device provider for updating your information and changing your privacy settings. Once Ember receives your information from a third party platform or wireless device, that information is stored and used by Ember in accordance with this Privacy Policy.

Please be aware that even after your account is terminated or deleted some or all of your information may still remain visible to others, including but not limited to any information that has been: (a) incorporated into other user’s content, comments, postings, submissions, including but not limited to cities, resources or other in-game assets; (b) copied, stored or disseminated by other users; (c) shared or disseminated by you or others such as in a Public Posting; or (4) posted on a third party platform. A request to delete and/or termination of your account will not result in the removal of information collected and already put in aggregate form or information that cannot  be removed by Ember. Ember is not able and/or obligated to remove any of your information from a third party platform.

 

You may opt out of receiving marketing communications and automated messages from us by using the unsubscribe link within each email, by managing notifications settings on your device or by contacting us to have your contact information removed from all promotional and transactional emails. However, even after you opt out from receiving promotional messages from us, you will continue to receive certain transactional messages from us regarding our products and services such as payment failure notices or account suspension notices sent via email.

 

It is necessary for us to process some of your personal data in order to allow you to use the Websites and/or the Services. To the extent the exercise of any of the rights described in this section prohibits us from processing your personal data, it may not be possible for us to continue to provide the Websites and/or the Services.

 

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Without limiting the previous sentence, if we have a business relationship with you or an entity you represent, we will retain your personal data for at least the duration of that relationship (subject to the exercise of any of your rights as a data subject). Otherwise, the length of time for which we retain information will depend on the nature of the information. Specifically:

Profile Data and Identity Data

We retain your profile data and identity data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate your account. Where we retain information for service improvement and development, we only use the information to uncover collective insights about the use of our services, not to specifically analyze personal characteristics about you.

Public Posts

Even if your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow other users to make full use of the social aspects of our Websites and Services. For example, we may continue to display content you have provided such as posts or responses.

Marketing information

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

Modifications to This Privacy Policy

From time to time, we may update this Privacy Policy to clarify our practices or to reflect new or different privacy practices, such as when we add new features, and Ember reserves the right to modify and/or make changes to this Privacy Policy at any time. If we make any material change we will notify you by prominent means such as by email notice sent to the email address specified in your account) or by posting a notice on the site or sending a push notification. Other modifications will become effective on the day they are posted unless stated otherwise.

 

Any notifications regarding changes that have been posted on Websites may be removed after 30 days. If you have not accessed the Websites and/or the Services within 30 days, please consult the top of this Privacy Policy to determine when this Privacy Policy was last revised as there may be changes that have occurred since your last visit.

 

If you continue to access and/or use the Websites or Services, including any of the Services available through any third party platform, after the effective date of any change, then such access and/or use will be deemed an acceptance of and an agreement to follow and be bound by the Privacy Policy as changed. The revised Privacy Policy supersedes all previous privacy policies. For this reason, we encourage you to review this Privacy Policy any time you access or use the Websites or Services, and recommend that you print out a copy for your records. Upon our request, you agree to accept or sign a non-electronic version of this Privacy Policy and any other policies or agreements set forth or available on or through the Websites or any third party platform.

 

International Transfers

Our business operates principally in the United States of America and to the extent we process your data directly we will do so in the United States. When you provide information to us directly, you are transferring that information to the United States. We will only transfer your data to third parties outside of the European Economic Area (a) if we have first obtained your prior consent; or (b) after taking such measures as are necessary to ensure the transfer is in compliance with the requirements of the GDPR. Such measures may include (without limitation) transferring your data to a recipient in a country that the European Commission has decided provides adequate protection for personal data, to a recipient that has achieved binding corporate rules authorization in accordance with the GDPR, to a recipient in the United States that has certified its compliance with the EU-US Privacy Shield, or to a recipient that has executed standard contractual clauses adopted or approved by the European Commission. The third parties outside the European Economic Area that we currently propose to transfer your personal data to are set forth on Exhibit A. Exhibit A may be updated from time to time.

 

 

Questions and Contact Details

Please feel free to contact us by:  

 

 

 

EXHIBIT A

THIRD PARTY PROCESSORS/SUB-PROCESSORS OF YOUR DATA

To support the Website and the Services, we use different service providers that may store and process personal data about you. This section provides important information about the identity, location, and role of these Data Processors/Subprocessors. We use different types of Processors/Subprocessors to perform various functions as explained in the table below.

Processor/Subprocessor

Location

Role

IronSource

 

Serving advertisements

Crashlytics

 

Crash reporting

GameAnalytics

 

Marketing and Analytics

AppsFlyer

 

Marketing and Analytics

Google Analytics

 

Analytics