Effective date:
Trans Fun Corporation Limited and its subsidiaries and affiliates (also referred to as “Company,” “we,”
“us,” or “our””) take your privacy very seriously. This Privacy Policy(the
“Policy”) is designed with your needs in mind, and it is important that you
have a comprehensive understanding of our personal information collection and
usage practices, while ensuring that ultimately, you have control of your
personal information provided to us when you use our mobile applications that
hyperlink to this Policy and are available for download in the or any app
store, including but not limited to Google Play Store, Apple App Store, or are
pre-installed on third party devices (the “Apps”), or any other content owned
or operated by us (collectively, the “Services”).
This Privacy Policy is part of, and is governed by, the terms and
conditions set forth in our Terms of Service located at http://policy.transfungames.com/Terms_of_Service.html
Please read this carefully before you use our Services. Ultimately, what we want is the best for all our
users. Should you have any questions with our data handling practices as
summarized in this Privacy Policy, please contact transfungames.com@gmail.com to address your specific concerns. If you disagree with anything in
this Policy, you must not use or access the Services.
If you are located in the European Economic Area,
United Kingdom and/or Switzerland, please also read Exhibit A carefully before you use our
Services.
If you are California Residents, we provide a separate <Privacy Notice for California Consumers> http://policy.transfungames.com/Privacy_Policy.html which addresses how we respect California's users' privacy. Please
also read carefully before you use our Services.
1. What information is collected by us and how do we use it
Under this Privacy Policy, “personal information” means information that
can be used to directly or indirectly identify an individual, either from that
information alone or from that information combined with other information We
has access to about that individual, except as otherwise specifically provided
by applicable laws in your region. We will use your personal information
strictly in accordance with this Privacy Policy. When you access or use our
Services, we may generally collect the personal information described below.
1) Information You Directly and Voluntarily Provide to Us
When you access or use our Services, you may provide the following
information to us:
a) Customer Support Information: If you are a visitor to the Site, or a user of the Apps, we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services.
b) Contact Information: When you sign up to create an account with some of our Apps, you will be required to provide an email address, phone number or other contact information as part of the registration process. Alternatively, you can use your Facebook Account or other third party social network accounts (together, “Social Media Account”) to register for the Services.
c) Social Media Account Information: When you sign up with a Social Media Account, you will be asked to choose which information you would like to share with us, such as your email address, birthday, friends list, or public profile information. When you decide to use a Social Media Account to sign up for our Services, we only require the collection of the email address associated with your Social Media Account; all other information provided by you is voluntary.
d) Profile Information: When using some of our Services, you may be able to add information to your profile, such as an avatar or profile picture, birthday, nickname or username, or country. You voluntarily provide this information to us.
e) Your Content: When using some of our Services, you can create, post, upload or share content by providing us with access to your photos, media and files, and your device’s camera and microphone. You voluntarily provide this information to us.
2) Information Automatically Collected Through the Services
We automatically collect information about you when you use the Services,
such as:
a) Device Information: If you access the Services through a mobile device, we may be able to identify the general location of your mobile device (not precise geolocation data), your mobile device’s brand, model, operating system, resolution, screen size, system version, Bluetooth settings, internet connection, random-access memory (“RAM”), the application you have installed, the applications you have running in the background, mobile device’s advertising ID, other unique identifiers and other information related to device setting.
b) Cookies & Similar Tracking Information: We use cookies and similar tracking technologies to collect information about your interactions with our Services. The information we collect includes, but is not limited to, account activation time, content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, URLs you have visited, notifications that have appeared on your mobile device, your Internet Protocol (“IP”) address, your mobile country code, and your user ID.
c) Content Sharing: When you choose to share content with us, we automatically collect information about your Wi-Fi connection, and call information.
You may be able to limit the amount of information collected from your
device (e.g., computer, phone, or tablet) with us by adjusting your device or
browser settings. However, by preventing us from collecting information from
you, we may not be able to provide some functions on our Services.
3) Information You Share on Third Party Websites or through Social Media Services
The Services may include links to third-party websites and social media
services where you may be able to post comments, stories, reviews or other
information. Your use of these third-party websites and social media services
may result in the collection or sharing of information about you by these
third-party websites and social media services. We encourage you to review the
privacy policies and settings on the third-party websites and social media
services with which you interact to make sure you understand the information
that may be collected, used, and shared by those third-party websites and
social media services.
We use the personal information we gather through the Services for the
purposes described below. If we use your personal information in any other
ways, we will disclose this to you. You can choose not to share your
information with third parties for marketing purposes, or from allowing us to
use your personal information for any purpose that is incompatible with the
purposes for which we originally collected it or subsequently obtained your
consent. If you choose to limit the ways we can use your personal information,
some or all of the Services may not be available to you.
1) To provide the Services to you. We require certain information from you in order to provide you with the Services you requested. Such information may include your contact and device information. We share this information with our service providers or partners to the extent necessary to continue to provide you with the Services. We cannot provide you with Services without such information.
2) To provide customer service. We process your personal information when you contact us to help you with any questions, concerns, disputes or issues, or to provide us with your feedback. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
3) To enforce terms, agreements or policies. To ensure your safety and adherence to our terms, agreements or policies, we may process your personal information to
a) actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services;
b) investigate, prevent, or mitigate violations of our terms and policies;
c) enforce our agreements with third parties and partners;
d) collect fees based on your use of our Services.
We cannot perform our Services in accordance with our terms, agreements or
policies without processing your personal information for such purposes.
4) To send you Service-related communications. We use your contact information to send you administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you. Service-related communications are not promotional in nature. You cannot unsubscribe from such communications because you could miss important developments relating to your account or the Services that may affect how you can use our Services.
5) For security purposes. We process your personal information to
a) improve and enforce our security measures; combat spam, malware, malicious activities or security risks;
b) monitor and verify your identity so that unauthorized users do not access your account with us.
We cannot ensure the security of our Services if we do not process your
personal information for security purposes.
For all purposes listed above, pursuant to the EU General Data Protection Regulation
or any equivalent legislation, we process the personal information of users
located in the European Economic Area, United Kingdom and Switzerland based
on our contract with you.
6) To maintain legal and regulatory compliance. We process your personal information to pay our taxes or fulfill our other business obligations, and/or to manage risk as required under applicable law.
We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes.
Pursuant to the EU General Data Protection Regulation or any equivalent legislation, we process the personal information of users located in the European Economic Area, United Kingdom and Switzerland to comply with our legal obligations.
7) To personalize your experience on the Services. We allow you to personalize your experience on our Services via social media plugins on our Services (e.g., Facebook, Google etc.), by keeping track of your preferences (e.g., nickname or display name, time zone, language preference, etc.), and more. Without such processing, you may not be able to access or personalize part or all of our Services.
Pursuant to the EU General Data Protection Regulation or any equivalent legislation, we process the personal information of users located in the European Economic Area, United Kingdom and Switzerland to satisfy our legitimate interests as described above.
8) To conduct research and development. We process information about the way you use and interact with our Services to
a) help us improve our Services; build new Services;
b) build customized features or Services. Such processing ensures your continued enjoyment of part or all of our Services.
Pursuant to the EU General Data Protection Regulation or any equivalent
legislation, we process the personal information of users located in the
European Economic Area, United Kingdom and Switzerland to satisfy our
legitimate interests as described above.
9) To engage in marketing activities. We may process your contact information or information about your interactions on our Services to
a) send you marketing communications; deliver targeted marketing;
b) inform you about events, webinars, or other materials, including those of our partners; and, keep you up with our relevant products and Services.
Transactional communications about your account or our Services are not
considered “marketing” communications. In addition, when you share your
friends’ contact information with us, we may reach out to them to invite them
to our Services and to continue receiving our communications. You can choose to
step out of our marketing activities at any time. Pursuant
to the EU General Data Protection Regulation or any equivalent legislation, we
process the personal information of users located in the European Economic
Area, United Kingdom and Switzerland based on the Section 9 of the
Policy.
2. How We Share Your Information
We may share your personal information with third parties in the following
circumstances:
1) Employees, Third-Party Processors and Third-Party Service Providers. We may disclose your personal information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the personal information needed to perform these limited functions on our behalf.For all purposes listed above, pursuant to the EU General Data Protection Regulation or any equivalent legislation, we process the personal information of users located in the European Economic Area, United Kingdom and Switzerland based on our contract with you.
2) response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policy.
To the extent permitted by law, we will disclose your personal information if:
a) required to do so by law, or in response to a subpoena or court order or similar request from judicial authority, law enforcement authorities or other competent public authorities;
b) we believe, in our sole discretion, that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or
c) we believe that you have abused the Services by using it to attack our systems or to gain unauthorized access to our system, to engage in spamming or otherwise to violate applicable laws.
3) Business Transfers or Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information owned or controlled by us may be one of the assets transferred to third parties. We will notify you via email or a prominent notice within our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred personal information will be subject to this Privacy Policy. However, any personal information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.Pursuant to the EU General Data Protection Regulation or any equivalent legislation, we process the personal information of users located in the European Economic Area, United Kingdom and Switzerland based on legitimate interests described above.
4) Our Affiliates. Based on your consent, we may share some or all of your contact information with our, parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out by contacting us. Pursuant to the EU General Data Protection Regulation or any equivalent legislation, we process the personal information of users located in the European Economic Area, United Kingdom and Switzerland based on your consent.
5) Third-Party Business Partners. Base on you consent, we may work with and share some of your information with our third-party advertising partners to provide you with advertisements or other tailored content. For more information about our own advertising practice and those of third-party partners, please visit our Ad Choice policy http://policy.transfungames.com/AD_Choice.html . We may share information related to users of our service with affiliates or unaffiliated third parties on a de-identified, aggregate basis. While this information will not identify you personally, in some instances these parties may be able to combine these aggregate ,de-identified information with other data they have about you, or that they receive from other parties, in a manner that allows them to identify you personally. Pursuant to the EU General Data Protection Regulation or any equivalent legislation, we process the personal information of users located in the European Economic Area, United Kingdom and Switzerland based on your consent.
3. How We Protect Your Information
We are committed to ensuring the security of your personal information. We
have physical, technical and administrative safeguards in place to protect the
confidentiality of your personal information. In addition, we require that our
service providers handling personal information also maintain appropriate
physical, technical and administrative safeguards to protect the security and
confidentiality of the personal information you provide to us.However, we
cannot guarantee the security of your personal information or that loss, misuse,
unauthorized acquisition, or alteration of your data will not occur. We also
have no way of protecting any of your personal information that is not in our
control, such as any information transmitted via email or wireless connections.
Maintaining the security of your personal information is also your
responsibility. Where we require you to register an account, you should choose
a password of sufficient length and complexity and keep your password
confidential. Do not leave your device unlocked so that other individuals may
access it. Make sure you trust the wireless connections you are using to access
or use our Services.
If you think there has been unauthorized access to or use of your account,
please contact us
4. How We Store Your Information
We will try to limit the storage of your personal information to the time
necessary to serve the purpose(s) for which your personal information was
processed, to enforce our agreement, policies or terms, to resolve disputes, or
as otherwise required or permitted by law. Please contact us if you have any
questions about our retention periods. While retention requirements can vary by
country, we generally apply the retention periods noted below.
1) Marketing. We store information used for marketing purposes indefinitely until you unsubscribe. Once you unsubscribe from marketing communications, we add your contact information to our suppression list to ensure we respect your unsubscribe request.
2) Your Interactions and Content on Our Services. We may store any information about your interactions on our Services or any content created, posted or shared by you on our Services (e.g., pictures, comments, support tickets, and other content) indefinitely after the closure your account for the establishment or defense of legal claims, audit and crime prevention purposes.
3) Web Behavior Data. We retain any information collected via cookies, clear gifs, webpage counters and other technical or analytics tools up to one year from expiry of the cookie or the date of collection.
4) Telephone Records. As required by applicable law, we will inform you that a call will be recorded before doing so. Any telephone calls with you may be kept for a period of up to six years.
5. Children
We do not knowingly collect personal information from children under 18
years old, unless permitted to do so by applicable law. Children are not
permitted to use our Services unless they provide us with consent from their
parent or guardian. If we become aware that we have unknowingly collected
personal information from a child, we will make commercially reasonable efforts
to delete such information in our database. If you are a parent or guardian of
a child, and you believe your child has provided us with their Personal
Information on our Services, please contact us .
6. Cookies and Other Tracking Technologies
1) What Are Cookies
Cookies are small text files containing small amounts of information which
are downloaded and may be stored on any of your internet enabled devices e.g.
your computer, smartphone or tablet - like a memory for a web page. This means
we automatically collect and store the following information about your visit:
the internet domain and IP address from where you access the Service;
the type of browser software and operating system used to access the Service;
the date and time you access the Service;
if you linked to the Service from another website, the address of that website; andthe pages you enter, visit and exit from the Service.
2) How We Use Cookies
We use the following cookies: Login related cookies;We use cookies when you
are logged in so that we can remember this fact. This prevents you from having
to log in every single time you visit a new page. These cookies are typically
removed or cleared when you log out to ensure that you can only access
restricted features and areas when logged in.
Site preferences cookies to set your preferences for how this site runs
when you use it. In order to remember your preferences we need to set cookies
so that this information can be called whenever you interact with a page is
affected by your preferences.
3) Third-party Analytic Service Provider
In some special cases we also use cookies provided by trusted third
parties. The following section details which third party cookies you might
encounter through this site. These cookies are likely to be
analytical/performance cookies or targeting cookies. You should refer to the
third parties’ own cookie and privacy policies for information about how they
may use your information.In particular, we use Google Analytics cookies to
obtain an overall view of visitor habits and visitor volumes, and to help
improve the overall experience of our Service.We use Google Analytics, a
third-party web analysis service provided by Google Inc, which uses “performance
cookies” and “targeting cookies” to analyze how you use the Website. The
information generated by the cookie about your use of the Website (including
your IP address) will be transmitted to and stored by Google on servers in the
United States. However, this website uses Google Analytics with the feature of
' IP Anonymization ', which means that Google will truncate/anonymize the last
octet of the IP address for Member States of the European Union. On behalf of
us, Google will use the information collected for the purpose of evaluating
your use of our Website, compiling reports on website activity and providing
other services relating to website activity and internet usage to us. Google
will not associate your IP address with any other data held by Google. You may
refuse the use of cookies by selecting the appropriate settings on your browser
as described above. Furthermore you can prevent Google’s collection and use of
data (cookies and IP address) by downloading and installing the browser plug-in
available under https://tools.google.com/dlpage/gaoptout?hl=en-GB# . You may
disable the use of Google Analytics by using the link disable Google Analytics.
This link creates an opt-out cookie which prevents the further processing of
your data. For more information about Google Analytics cookies, please see
Google's help pages and privacy policy. If you do not accept the use of these
cookies, we cannot guarantee how our Website will perform for you.You can find
more information about the Google Analytics cookies
here:https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie
usage .
Besides Google Analytics, we also use Facebook Insight to help us know
better our website page performance, like demographic data about our audience.
With Insight, we can use understand how people are engaging with our page, view
metrics about our page's performance. Please note that we do not merge
personally-identifiable information with the non-personally identifiable
information collected through any third-party analytics service.
You can learn more on how Facebook to collect and use your cookies from
https://www.facebook.com/policies/cookies/
4) Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your
browser (see your browser Help for how to do this). Be aware that disabling
cookies will affect the functionality of this and many other websites that you
visit. Disabling cookies will usually result in also disabling certain
functionality and features of this site. Therefore.it is recommended that you
do not disable cookies.
For more information about how to do this, please see
http://www.allaboutcookies.org/manage-cookies/clear-cookies-installed.html , or
follow the 'Help' option in your internet browser for more details.
To block Google Analytics cookies specifically, you can install the “Google
Analytics Opt-out Browser Add-on” provided by Google. If you share the use of a
computer, accepting or rejecting the use of cookies may affect all users of
that computer.
5) More Information
Hopefully that has clarified things for you and as was previously mentioned
if there is something that you aren't sure whether you need or not it's usually
safer to leave cookies enabled in case it does interact with one of the
features you use on our site.However if you are still looking for more
information, you can contact us.
7. Amendments to this Policy
We may periodically make changes to this Policy as we update or expand our
Services. We will notify you of any material changes to this Privacy Policy by
notifying you via the email we have on file for you, or by means of a notice on
our Services in advance of the effective date of the changes. If you do not
agree to the changes, you should discontinue your use of the Services prior to
the time the modified Policy takes effect. If you continue using the Services
after the modified Policy takes effect, you will be bound by the modified
Policy.
Furthermore, we may provide you with “just-in-time” disclosures or
additional information about the data collection, use and sharing practices of
specific Services. These notices may provide more information about our privacy
practices, or provide you with additional choices about how we process your
personal information
Exhibit A European Economic Area, United Kingdom and/or Switzerland
This section only applies to users of our Services that are located in the
European Economic Area, United Kingdom and/or
Switzerland (collectively, the “Designated Countries”) at the time of
data collection. We may ask you to identify which country you are located in
when you use some of the Services, or we may rely on your IP address to
identify which country you are located in. Where we rely on your IP address, we
cannot apply the terms of this section to any user that masks or otherwise
obfuscates their location information so as not to appear located in the
Designated Countries. If any terms in this section conflict with other terms
contained in this Policy, the terms in this section shall apply to users in the
Designated Countries.
1) Our Relationship to You
We are data
controllers with regard to any personal information collected from users of its
Services. A “user” is an individual providing personal information to us via
our Services, such as by creating an account with our Apps, signing up for our
newsletter(s), or otherwise accessing or using our Services. A “data
controller” is an entity that determines the purposes for which and the manner
in which any personal information is processed. Any third parties that act as
our service providers are “data processors” that handle your personal
information in accordance with our instructions.
2) Legal bases for processing Personal Information
We describe our legal bases for processing in Section 1(“How We Use the
Information We Collect”) and Section 2 (“How We Share Your Information with Third Parties”) under headings entitled “Designated Countries.” The
legal bases on which we rely on to process your personal information include:
your consent to the processing; satisfaction of our legal obligations;
necessity to protect your vital interests; necessity to carry out our
obligations arising from any contracts we entered with you or to take steps at
your request prior to entering into a contract with you; necessity to process in
the public interest; or for our legitimate interests as described in those
sections.
3) Marketing Activities
If you are located in the Designated Countries and are a current user, we
will only contact you by electronic means (such as email or SMS) per your
communication preferences and/or with information about our Services that are
similar to the Services you previously purchased from us or negotiated to
purchase from us.For new users located in the Designated Countries, we will
contact you by electronic means for marketing purposes only based on your
consent or based on your friends’ consent. You can always withdraw your consent
or change your marketing communication preferences at any time and free of
charge. To opt out of the emails, please click the “unsubscribe” link in the
footer of marketing emails or contact us. Marketing communications are
promotional in nature and do not include transactional or Service-related
communications.
4) Individual Rights
We provide you with the rights described below when you use our Services.
Please contact us if you would like to exercise your rights under applicable
law. When we receive an individual rights request from you, please make sure
you are ready to verify your identity. Please be advised that there are limitations
to your individual rights. We may limit your individual rights in the following
ways:
Where denial of access is required or authorized by law;
When granting access would have a negative impact on other's privacy;
To protect our rights and properties;
Where the request is frivolous or burdensome.
a) Right to withdraw consent. If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
b) Right of access and rectification. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.
c) Right to be Forgotten. You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
d) Right to restriction. You have the right to restrict our processing your personal information where one of the following applies:
You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;
The processing is illegal and you oppose the erasure of your personal information and request the restriction of its use instead;
We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
We will only process your restricted personal information shall with your
consent or for the establishment, exercise or defense of legal claims or for
the protection of the rights of another natural or legal person or for reasons
of important public interest. We will inform you if or when the restriction is
lifted.
e) Right to object to processing. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
f) Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
g) Notification to third-parties. If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.
h) Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.
i) Right to file a Complaint. If you believe we have infringed or violated your privacy rights, please contact us so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.
5) Transfer of Personal Information
If you choose to use the Services or provide your information to us, your
personal information may be transferred to, processed and maintained on servers
or databases located outside of the country or jurisdiction where you are
located. Such countries or jurisdictions may have data protection laws that are
less protective than the laws of the jurisdiction in which you reside. If you
do not want your information transferred to or processed or maintained outside
of the country or jurisdiction where you are located, you should not use the
Services.
Designated Countries: We transfer your personal information subject
to appropriate safeguards as permitted under the Data Protection Laws.
Specifically, when your personal information is transferred out of the
Designated Countries, we have the required contractual provisions for
transferring personal information in place with the third-parties to which your
information is transferred. For such transfers, we rely on legal transfer
mechanisms such as Standard Contractual Clauses or we work with U.S. based
third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy
Shield Framework.
Effective on
This notice is designed to
supplement the information described in our Privacy Policy http://policy.transfungames.com/Privacy_Policy.html and applies solely to users who reside in the State of California
(“consumers” or “you”). We prepare this separate Privacy Notice for
California Consumers to comply with the California Consumer Privacy Act of 2018
(“CCPA”) and other California privacy laws.
1. The Categories of
Personal Information
Please find the categories of personal information in Exhibit A. We collect information that identifies, relates to, describes,
references, is capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular consumer or device (“personal
information”). In particular, we have collected the following categories of
personal information from consumers.
2. How We Use Your
Personal Information
If you want to know the business
purposes for which we may use or disclose the personal information, you can
visit our Privacy Policy and see Article 4.
3. We Do Not Sell Your
Personal Information
As CCPA requires, we need to
disclose to you whether we sell your personal information.
We have not sold your personal information over the preceding 12
months. So, we do not offer an opt-out to the sale of personal information.
4. How We Share Your
Personal Information
We may disclose your personal
information to a third party for a business purpose. When we disclose personal
information for a business purpose, we enter a contract that describes the
purpose and requires the recipient to both keep that personal information
confidential and not use it for any purpose except performing the contract.
In the preceding 12 months, we have
disclosed the following categories of personal information for a business
purpose:
1) Identifiers
• Our affiliates;
• Ads Content Service provider.
• Ads analytic Service provider;
2) Internet or other similar network activity.
• Our affiliates;
3) Geo-location data.
• Our affiliates;
4) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
• Our affiliates;
• Ads Content Service provider.
• Ads analytic Service provider;
5) Commercial information.
• Our affiliates;
• Third parties to whom you or your agents authorize us to disclose
your personal information in connection with products or services we provide to
you.
6) Sensory data.
• Our affiliates;
7) Inferences drawn from other personal information.
• Our affiliates;
5. Your Rights and
Choices
The CCPA provides consumers with
specific rights regarding their personal information. This section describes
your CCPA rights and explains how to exercise those rights. Under the CCPA, we cannot collect new categories of
personal information or use them for materially different purposes without
first notifying you.
1) Your Right to Request for Information
As required by CCPA, you or your
authorized agent have the right to request us to disclose information to you
about how we collect, use and share your personal information over the past 12
months, including the categories of personal information we collected; the
categories of sources for personal information we collected; our business
purpose for collecting that personal information; the categories of third parties
with whom we share that personal information.
2) Your Right to Delete Information
You or your agent have the right to
request that we delete your specific personal information that we collected
from you and retained, except in the following cases Such cases include:
· to detect security incidents, protect against
malicious, or illegal activity;
· to identify and repair application errors that impair
existing intended functionality;
· to exercise free speech, ensure the right of another
consumer to exercise their free speech rights, or exercise another right
provided for by law.
· to conduct internal uses that are reasonably aligned
with your expectations based on your relationship with us;
· and other cases provided by CCPA and other California
laws.
3) How You Exercise Your Rights Under CCPA
To exercise your rights described
above, please submit a verifiable consumer request to us by either:
· Email to transfungames.com@gmail.com.
Only you or your authorized agent
may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for request for information
twice within a 12-month period. A verifiable consumer request must:
· Provide sufficient information that allows us to
reasonably verify your identity and make us confirm we collected personal information about
you.
· Describe your request with sufficient details that
allows us to understand and respond to it.
We cannot respond to your request
accurately if we cannot verify your identity.
4) How We Respond Your Request
We would respond to your verifiable
consumer request within 45 days. If we need more time (up to 90 days), we will
reply to you the reason and extension time. We will deliver you our written
response by email, telephone or other electronic means. Any
disclosures we provide will only cover the 12-month period preceding our
receipt of your request. The response may also explain the reasons we cannot
comply with a request, if applicable.
We won’t charge you a fee to respond
to your consumer request. But under CCPA, if your request is excessive,
repetitive, or manifestly unfounded, we have a right to ask you to bear a fee
for your request. On this case, we will tell you the reason and provide
you with a cost estimate.
5) Non-Discrimination for Exercising Your CCPA Rights
We will not discriminate against you
for exercising any of your CCPA rights. Such discrimination include: denying
you our services; charging you different prices or rates for our services;
providing you a different level or quality of our services; suggesting that you
may receive a different price or rate for services or a different level or
quality of services.
6. Changes to Our
Privacy Notice
We reserve the right to revise this
notice at our discretion. When we make important changes to this notice, we
will notify you through a notice on our website homepage(http://policy.transfungames.com) and internal page of our applications
7. Contact Information
If you have any questions about this
notice, please do not hesitate to contact us at:
Email: ;transfungames.com@gmail.com
Exhibit A
|
Category |
Examples |
Sources |
|
Identifiers. |
A unique device identifier, online
identifier (such as Android ID, Google Advertising ID, Identifier For
Advertising), Internet Protocol address, email address or other similar
identifiers. |
You provide directly and through
your interactions with our services. Through our business partners,
such as ad technology providers that help us serve users relevant ads and
understand the ads’ effectiveness |
|
Internet or other similar network
activity. |
Browsing history, search history,
information on a user's interaction with or website, application, or
advertisement. |
Through your interactions with our
services. |
|
Geo-location data. |
Physical location or movements. |
You provide directly; and through your interactions with
our services. |
|
Personal information categories
listed in the California Customer Records statute (Cal. Civ. Code §
1798.80(e)). |
A name, telephone number. |
You provide directly. |
|
Commercial information. |
Records of personal property,
products or services purchased, obtained, or considered, or other purchasing
or consuming histories or tendencies. |
You provide directly, through your
interactions with our services ; and from our business partners. |
|
Sensory data. |
Audio, electronic, visual, or
similar information. |
You provide directly. |
|
Inferences drawn from other
personal information. |
Profile reflecting a person's
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.[1] |
You provide directly or through
your interactions with our services. |