Privacy Policy

Effective Date: [July 31st], 2020

This Privacy Policy applies to Cinamon Games (the “Company”), and its websites and related services such as mobile application games, which we here collectively call the “Service”. We may periodically update this Privacy Policy by posting a new version. If we make any material changes, we will notify you by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy. By using the Service, you are expressing your agreement to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Service.


I. Information We Collect From Your Use Of Our Services

· Device information

We may collect device-specific information, such as your hardware model, operating system version, mobile unique device ID (UDID or IMEI), and mobile network information including phone number.

· Log information

When you use our services, we may automatically collect and store certain information in server logs. This may include: Details of how you used our service, such as your search queries.

· Internet protocol address

Device event information such as crashes, system activity, hardware settings, language.

· Location information

When you use a location-enabled service, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.

· Unique application numbers

Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to us when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.

· User Created Content

We may collect the content you create when you use our Service, including any content in which you have provided voluntarily with consent.

· Identifier

When you use our Service, we may collect unique personal identifiers.

· Commercial information

We may collect commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

· Internet or Other Electronic Network Activity Information

We may collect internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

· Inferential Information

We may collect inferences drawn from any of the information identified in this Section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


II. Information Provided to Cinamon Games by Third Parties.

We may also use other anonymized information from third parties, including in connection with the operation and distribution of our products and services as well as market and demographic studies that we use to supplement personal and anonymous information collected or provided directly by you. Some third party services such as Apple, Twitter and Facebook may also provide us with information from your accounts there with your permission.

By playing Cinamon Games games through a social network or other third party platform or service or by connecting to such a third party network, platform or service via one of our products and/or services, you are authorizing Cinamon Games to collect, store, and use in accordance with this Privacy Policy any and all anonymized information that you agreed the social network or other third party platform could provide to Cinamon Games through the social network/third party platform Application Programming Interface (API) based on your settings on the third party social network or platform. Your agreement takes place when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, “accept” or “allow” (or similar terms) one of our applications through a social network, or other third party platform or service.

You may be able to log in to the Service by connecting your account in third-party platforms such as Facebook and Apple to the Service. Such third-party platforms will authenticate your identity for the Service. The information we collect when you connect your user account on such a third-party platform to the Service is the platform in which you connected your account to.

We may also receive anonymized information from third parties in connection with market and demographic studies and/or other data that we use to supplement personal information provided directly by you.


III. Disclosure and Transfer to Third Parties

We generally do not disclose or transfer any personal information about our customers, prospects, or visitors to any third parties. We may however, disclose and transfer data which does not contain or reveal any personally identifiable information or is specifically attributable to you to our business partners, third party analytics service providers, ad networks and advertisers (collectively, "Partners"). Provided, however, some Partners may also act as third party service providers (described below) to us and may have access to your personally identifiable information. Moreover, Partners may obtain public information about you from your profile or other public sources.

We may also periodically engage in co-marketing activities, where we work with a complementary solution provider to launch a joint marketing program. In these situations, we will only send information to you on behalf of the other; we do not provide your personally identifiable information to such a partner. We may also enter into business partnerships with other parties to provide specific services. If a user signs up for these services or responds to a particular marketing offer, we may share personally identifiable information that is necessary for our business partner to provide these services or get in contact with you only if you gave us consent or directed us to do so.

We may provide your non-identifiable information to our "Affiliates" (which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership located in the United States, Japan or anywhere else in the world) for the purpose of transferring and processing such information based on our instructions and such purposes as described in this Privacy Policy and in compliance with this Privacy Policy and other appropriate confidentiality and security measures.

Disclosure of your personally identifiable information described in Sections I and II above may occur when we engage or employ service providers, vendors or other third parties to facilitate the provision of our Services (including, without limitation, payment processing, data analysis, e-mail delivery, hosting services, customer service and promotional services) to provide the Services on our behalf, or to assist us in analyzing how our Services are being used only if you gave consent or directly shared your personal information to us or the third party. Such third party service providers may have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your non-identifiable information may be transferred with the business or a part of it to the successor organization in such transaction. If material changes to the Company’s privacy practices will occur as a result of such a transaction, we will notify you and other users in the manner described in this Privacy Policy.

In addition, upon the expiration or a termination of any third party license arrangements involving one or more parts of the Service, your non-identifiable information (including device, log, location, and game-related user information) may be transferred to the subject third party licensor in accordance with the terms of the applicable license agreement. In advance of such transfer to a third party licensor, the Company will notify you and other users in writing in the manner described in this Privacy Policy.


IV. Data Transfers, Storage, and Global Processing

The computer systems on which Cinamon Games collects, stores, and uses the information it collects or receives are based in the Republic of Korea. Your information may be transferred to, used, processed or held by Cinamon Games in other countries, including countries outside your country of residence both in and outside the United States, the European Union and Asia, and used for the purposes set out in this Privacy Policy.


V. How We Use the Information We Collect

We may use the information we collect through your use of our services for providing enhanced game services and promotional information regarding Cinamon Games. For example, we may use the information we collect in any of the following ways:

• Creating your Game Account and managing the account information.

• Informing you of (a) products, new products, services, features, promotions, enhancements, and updates regarding our service and (b) updates to the Cinamon Games Policy.

• Promoting and facilitating your use of our service, including the targeted advertising and affiliate marketing.

• Marketing Cinamon Games games to you, including sending you offers, promotion information, newsletters, local or push notifications, e-mail campaigns, and communications regarding new, improved or existing Cinamon Games.

• Providing customer support and responding to user inquiries.

• Fulfilling your request and/or order for Cinamon Games and our obligations under the Cinamon Games Policy.

• Enabling user-to-user communication and interaction.

• Soliciting your input and feedback to improve user experience.

• Monitoring the technical functioning of our service.

• Developing new and/or improved games, products, services or offerings.

• Analyzing market trends and user traffic.

• Trouble-shooting errors or issues with any of our services.

• Complying with applicable laws, regulations, or administrative orders.

Also, Cinamon Games may combine your information in an attempt to provide you with a better user experience, to improve the quality and value of our service.


VI. Third Party Sites and Collection and Use of Information by Third Parties

Our website and mobile products may contain advertising or services which link to other websites such as Twitter, Facebook and YouTube. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. If you click on a link to a third party site, including on an advertisement, you will leave our mobile product you are using and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as Cinamon Games. We encourage you to review the privacy policies of any other service provider from whom you request services.

Our Services may contain third-party tracking and data collection and analytics tools from our Partners, examples of which include AppsFlyer (https://www.appsflyer.com). Such third parties may use APIs and SDKs in our Services to enable them to collect and analyze user and device related data and information. The third parties may have access to and collect data and information about you, such as your device identifier, geo-location information, IP address, application usage, access and session times, applications present on the device or in use at a particular time on the device, and your viewing of and interactions with advertising, for the purpose of providing their services, including, for example, enabling, providing and delivering advertising as described in further detail below.

The privacy policies of our Partners may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.

To the extent we display advertising in our Services, we may allow advertising networks of our affiliates and Partner networks to collect information about your mobile device to enable them to serve targeted ads to you.

You may also limit data collection by third parties by using your mobile device settings. Please note that electing to opt-out will not stop advertising from appearing in your application. It may make the ads you see less relevant to your interests. Additionally, please note that if you use a different mobile device or erase cache from your application, you may need to renew your opt-out choices.


VII. Accessing and Updating Your Personal Information

Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.


VIII. HOW DO WE PROTECT YOUR DATA

Security Safeguards.

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Data retention.

We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.


IX. AGE-RELATED DISCLOSURE

Our terms require that all our users be the age of 17 or above. Thus, please note that this Section is provided herein for the purpose of complying with the applicable laws and regulations only.

We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about teenagers under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about teenagers under the age of 13, please contact us. We also do not sell the personal information of minors under 16 years of age without affirmative authorization.


X. CALIFORNIA RESIDENTS & CCPA

Under the California Consumer Privacy Act of 2018 (“CCPA”), if you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in respect of the personal information we hold about you.

Please see above for:

  • categories of personal information collected about you in the last 12 months (see Sections I and II)
  • categories of personal information disclosed for business purposed (see Sections I, II and III)
  • We have not sold personal information to third parties within the last 12 months.

    You have the right to:

  • request that we disclose to you the following:
    1. the categories of personal information we collected about you;
    2. the categories of sources for the personal information we collected about you;
    3. our business or commercial purpose for collecting or selling that personal information;
    4. the categories of third parties with whom we share that personal information.
    5. the specific pieces of personal information we collected about you;
    6. the categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold; or
    7. the categories of personal information that we disclosed about you for a business purpose;
  • request deletion of your personal information;
  • opt-out of the sale of your personal information (if your personal information is being sold); and
  • not be discriminated against for exercising any of your rights under the CCPA.
  • To make a verifiable consumer request of disclosure or deletion, please contact us by email at [email protected] We may verify your request by asking for proof of identity such as your device ID and account information.


    XI. Changes to This Privacy Policy

    From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you by posting a notice on the Service if these changes are material and, where required by applicable law, we will obtain your consent.


    XII. Contact Information

    If you have questions or concerns regarding this Privacy Policy, please send an email to [email protected]

    Company: Cinamon Games

    Name of the controller: Doosun Hong

    Address: 28, Hyoryeong-ro 77-gil, Seocho-gu, Seoul, Republic of Korea

    email: [email protected]