Effective Date: January 4, 2017
The following policy states the practices that may impact you as a registered user with full access to our Services or a non-registered user of our Services (each a “Kirb User”). For information regarding the collection and use of Personal Information (defined below) from children under 14 years old, see the Section below, entitled “Our Policy Toward Children”.
Collecting Personal Information and Non-Identifying Information
Both Personal Information or Non-Identifying Information may be used alone or in the aggregate with information collected from other Kirb Users. Our primary objective in collecting any Personal Information or Non-Identifying Information is to provide you with a superior and personally relevant user experience.
In connection with registration of Kirb Users on our Services, we collect Personal Information which may include your email address, as well as information on mobile device type, mobile carrier, unique mobile device identifier (“Device ID”), Internet Protocol (“IP”) address and geo location, as applicable. We use your Device ID to make it possible to authenticate and understand your use of our Services, or the Third Party Application that you may choose to access through our Services.
Related to this information collection, our Services may serve ads that contain links to other Third-Party Mobile Applications, and we may utilize your Device ID to track clicks or other ad fulfillment metrics. Our use of your Device ID does not enable us to identify you personally, and we do not store this information in connection with your Kirb User account information. You may also be asked explicitly to provide Personal Information or Non-Identifying Information anytime that you are in contact with Kirb.
Additional Collection of Information
If you choose to link your Kirb account to an SNS, Personal Information that you independently submit to an SNS may be collected and used by us in order to provide you with enhanced functionality. In these instances, you consent to Kirb’s access and use of your username, alias and any other Personal Information you have independently provided to and made accessible through the SNS. Such access will be in accordance with the privacy settings you have set in your SNS account, if any. Similarly, we may use Personal Information that you have provided to us to help you establish social connections with other Kirb Users.
If you choose to participate in a Promotion, We may request that you provide us with Personal Information such as your email address or mailing address in order to administer your participation in the Promotion.
In connection with use of our Services or Third-Party Mobile Applications, in addition to information on device type, mobile carrier, IP address, platform version, and geo-location, as applicable, we may also collect navigation, interaction and engagement information regarding Kirb Users.
Cookies & Related Technologies
We use “cookies” to study traffic patterns and understand the effectiveness of marketing communications. Cookies we use can reveal, for instance, which pages are the most popular, how much time Kirb Users are spending there, and how they are interacting with the content on such pages.
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. If you do not accept cookies, however, you may not be able to view or use all portions of our Services due to limited functionality.
Some of our Services, including email messaging, use “click-through URLs” linked to other content on our Services. We track this click-through data to help us determine interest in topics, Services usability and other measures of Kirb User engagement.
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 hard drive. Pixel Tags allow us to count users who have visited certain pages of the Sites, to deliver branded services and to help determine the effectiveness of promotional or advertising campaigns.
When you use our Services or Third-Party Mobile Applications, our servers automatically record information that your browser or the applicable Service or Third-Party Mobile Application sends (“Log Data”). This Log Data may include information such as your computer’s or mobile device’s IP address, browser type, language, Internet Service Provider (ISP), referring and exit pages, time spent, information searched for, time and date stamp, clickstream data and other statistics. We use this information to monitor, analyze and understand trends, for technical administration of Services and Third-Party Mobile Applications, and to gather demographic information about our Kirb User base as a whole. We and Third Party Publishers may use this information for product and services improvements, and in marketing and advertising services.
Disclosures Within Kirb Services
As a user, you may create your own profile, connect with other Kirb Users of Services, send messages and transmit information through various channels. Please remember that any communications you have via our Services, depending on, for example, the functionality of any Kirb Application or Third-Party Mobile Application connected to our Services, may reveal your screen name and the content of your communications, making this information publicly available to other Kirb Users. Kirb is not responsible for the activities of other Kirb Users or other third parties with whom you choose to provide your Personal Information or otherwise interact.
With Third Parties for Industry Analysis
In addition to sharing aggregated Non-Identifying Information with Third Party Publishers, we may also share aggregated Non-Identifying Information with advertisers and ad networks (“Advertising Entities”) with whom we have strategic relationships. Unless you specifically opt in to share your Personal Information, the information that we share with these third parties will only be used in the form of Non-Identifying Information to support user trend analyses and demographic profiling. Some Third Party Publishers and Advertising Entities also act as Service Providers (defined below) to us, so in those cases we will share your information as described below.
With Preferred Partners
We may share your username, email address and Device ID (collectively, “Specific Shared Data”) with certain of our Third Party Publishers and other business partners (“Preferred Partners”) for those parties to assist us with providing you with the aspect of the Services for which you provided such Specific Shared Data to us, and to use such Specific Shared Data to provide you with information and marketing materials about Third Party Applications and other products and services in order, for example, to further enhance your use of our Services and to augment your gaming experience generally. In addition, in the event of a user inquiry concerning Third Party Publishers or Third Party Applications, we may send Specific Shared Data as well as the inquiry to the Third Party Publisher to address the inquiry.
We only share such information with Preferred Partners pursuant to an agreement by which the Preferred Partner is under obligations not to disclose or use it for any other purpose. You may contact us by any of the means provided in the “Contacting Us” section below to request not to have such information provided to Preferred Partners, understanding, however, that if such information is not shared with Preferred Partners it may affect your ability to use or access portions of the Services.
Some Preferred Partners also act as Service Providers (defined below) to us, and in those cases we may also share Personal Information and Non-Identifying Information as described below.
With our Service Providers
Disclosure of your Personal Information and Non-Identifying Information may also occur where we engage or employ service providers, vendors or other third party entities to facilitate provision of our Services (each a “Service Provider”) (e.g., without limitation, improvement of our Services’ features, user account authentication, promotion and marketing, administration, analytics, virtual currency transactions, crowd-sourcing, cloud storage and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Under Special Circumstances
At times, 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 Kirb or a third party, to protect the safety of the public or any person or to prevent or stop activity we may consider to be or to pose a risk of being, any illegal, unethical or legally actionable activity. Such disclosures shall only happen with written request by the agency for the requested information.
Under another special set of circumstances, for example, 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 Kirb’s assets, including your Personal Information.
Our Services require that you are the age of majority or have been legally emancipated pursuant to the laws your local jurisdiction.
For location-based Services, we may collect, use, and share precise location data, including the real-time geographic location of your computer or mobile device. Unless you explicitly opt-in to permit the use and sharing of your Personal Information regarding your geographic location, your location data will only be collected and used anonymously in a form that does not personally identify you. When you opt in to Third Party Application providers’ location services, we will share your geographic location with such Third Party Application providers in connection with their location services. Please note that some location-based services may require your Personal Information for the feature to work as intended.
Protecting Personal Information
Kirb takes your privacy very seriously and employs administrative, physical and electronic measures to safeguard your information from identity theft and unauthorized access. We do not and will not, at any time, request your credit card information, your account ID, login password or national identification numbers in a non-secure or unsolicited communication.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Sites in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Changing or Removing Information
You may email us at [email protected] to request that we delete your Personal Information from our database. 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 legitimate business purposes. Specific Shared Data cannot be retrieved from Preferred Partners after its disclosure.
Where you share information with other users through the communication channels of our Services, you generally should not expect to have any ability to modify or remove such communications. Nor should you expect us to modify or delete your comments upon your request.
If you participate in a Promotion hosted by us (where you may or may not disclose the information requested), you have the option to opt out at any time from such participation and the receipt of any related communications. Please follow the unsubscribe instructions provided in the relevant communications.
Links to Other Websites and Services
If a Kirb User chooses to participate in offer-linked information requests or “clicks on” an advertisement or another third party link, such Kirb User may be directed to that third party’s website or service and/or be prompted to provide Personal Information in connection with such activity. The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party’s privacy or information security policies or practices or their compliance with laws. We do not exercise control over third party websites or services. These other websites or services may place their own cookies or other files on your computer or mobile devices; collect data; or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. You have the responsibility to review the privacy policies and related statements of the other websites and services you use and the terms of the offers in which you participate. You agree that Kirb is not responsible for, nor will it be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information you voluntarily choose to provide to them.
California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To exercise such rights, California residence may contact us at: [email protected]
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 email address above.
This Agreement was last updated on: January 4, 2017