Privacy Policy

INTRODUCTION


Cynking values your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information you provide to us.

The use of our services may involve the collection and use of your Information (as defined in the "The Information We Collect and How We Collect It" section below) on our services (including our websites and mobile applications). It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully.

By using our services, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time.

SCOPE OF THIS PRIVACY POLICY


This Privacy Policy applies across all of our services. In addition, some of our services have specific privacy guidance applicable to their use. Such service-specific privacy guidance are incorporated into and form part of this Privacy Policy. If any service-specific privacy guidance says something different from this Privacy Policy, the service-specific privacy guidance will apply to the extent of the difference.

This Privacy Policy is incorporated into and form part of the Terms of Service that you have agreed to in order to use our services. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the Terms of Service , unless otherwise defined in this Privacy Policy or the context requires otherwise.

Please also note that this Privacy Policy does not apply to Information collected: (i) through third party services (including any third party websites) that you may access through our services; or (ii) by other companies and organisations who advertise their services on our services.

HOW DO WE COLLECT INFORMATION ABOUT YOU AND WHY?


We may collect information about you directly from you and from third parties, as well as automatically through your use of our Applications or Services.

INFORMATION WE COLLECT FROM YOU AND YOUR USE OF OUR APPLICATIONS AND SERVICES


We may receive certain information about you from third parties, such as Google or Apple. For information about how a third party may collect and disclose your information, please consult the third party’s respective Privacy Policy. We have no control over how the third party uses or discloses the personal information you provide to it. We store the information that we receive from the third party along with other information that we collect from you or receive about you. The information we receive depends on factors such as the Applications or Services you’re using, the third party, and your privacy settings. For example, we may collect and store some or all of the following information shared by the third party:
• your first and last name;
• your profile picture or its URL;
• your user ID number and profile information;
• your login e-mail provided to the third party;
• your physical location and that of the devices you use to access our Services;
• your gender;
• your birthday and/or age range;
• information about your activities through the third party;
• other publicly-available information provided by the third party; and/or
• any other information that the third party shares with us.

You may also share information with us directly. Certain areas and features of the Applications may require registration, account set-up and verification, including verification that you are over the age of 18 in order to complete your registration. You may be asked to give us some or all of the following information:

• your age or birthday;
• your first and last names;
• your e-mail address; and
• a password.

You may be able to take part in certain activities on our Applications and through our Services that enable you to communicate or share information with us and other players.
These include:
• participating in player forums and message boards;
• posting public comments to player profiles or gameboards;
• sending private messages or invitations to other players;
• chatting with other players; and/or
• posting photos.

We may use information that you disclose while engaging in any of these activities to protect the safety and well-being of our players and the Company’s rights and property in connection with our Applications and Services; to conduct research; to operate, improve, personalize and optimize our Applications and Services and our players’ experiences, including through the use of analytics; to manage and deliver contextual advertising; and for purposes described below. We may also obtain and share the billing and payment information that you provide when your purchase is processed by someone else, like Apple or Google.

If you purchase virtual currency or virtual items using our Services in connection with our Applications, we may have a third-party payment processor that will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information.

INFORMATION WE COLLECT AUTOMATICALLY:DEVICE IDS, COOKIES, AND OTHER TRACKING TECHNOLOGIES


We may use cookies, including Flash cookies, transparent GIFs, server log analysis and other tracking technologies, currently existing and as they are developed, to enhance your experience with the Applications and Services and track information about your use of our Applications and Services. Like many websites, our Site and third parties acting on our behalf, like Google Analytics, also store log files and use cookies and other tracking technologies to collect information.

We may automatically collect the following information about you, for example:

• language information, referring and exit pages, and URLs;
• your geolocation (with your permission),
• unique device identifier (as permitted),
• your computer or mobile device’s operating system and platform,
• the communication network associated with your computer or mobile device, and mobile device name and model,
• the date and time of your use of the Site, Applications and Services, and
• the length of time you play our Applications, and/or visit or use our Site and Services.
We may use this information in the aggregate or we may combine it with personal information about you.
Cookies are small text files placed on your device that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well.

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third-party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our promotional email messages or newsletters to tell us if you open and act on them.

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables our third-party analytics and advertising partners to access the mobile IDs.

We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site (or use our app). We and our partners also use these technologies to collect personal information about your online activities over time and across different websites or online services. This information is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, deliver and tailor interest-based advertising, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the information we collect or infer with third parties for these purposes.

HOW WE USE YOUR INFORMATION


We may use your Information for any of the following purposes:
• to provide our services to you;
• for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of our services;
• to provide you with advertising (as discussed in more detail under the "Advertising" section below);
• to better understand how you access and use our services, for the purposes of trying to improve our services and to
respond to customer desires and preferences, including language and location customisation, personalised help and instructions, or other responses to your and other customers’ usage of our services;
• to help us develop our new services and improve our existing services;
• to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with our services;
• for the purposes of software verification or administering software upgrades; and
• to allow you to participate in surveys and other activities about our products and services.

Please note that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where you have consented, Personal Information collected through one of our services may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualised manner).
For example, Personal Information collected during your use of one of our services may be used to suggest particular content that can be made available to you on another service or be used to try to present more relevant advertising to you in another service. You may also from time to time ask us to migrate or export your Personal Information contained in one of our services to another of our services, where such migration option is available. If any of your Personal Information comprises Your Content (as defined in the Terms of Service ), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the "Your Content" section of the Terms of Service .

Our service-specific privacy guidance may more particularly describe how we use Personal Information within the relevant services.

As noted under the "Use of your device by our services" section in the Terms of Service , we may require access to or use of your Personal Information within your device in order to provide our services to you. Any Personal Information that we use or access within your device will be treated in accordance with this Privacy Policy and the Terms of Service .

SHARING OF YOUR PERSONAL INFORMATION


Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes.

We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, mapping services providers who assists us and you with location data, analytics partners who assist our business, and advertising partners on our serices). In addition, we may allow such third parties to collect your Personal Information across our services. In each case, we permit such sharing and/or collection for the purposes of: (i) providing our services to you; (ii) assisting us in carrying out the purposes set out under the "How We Use Your Information" section above; (iii) carrying out our obligations and enforcing our rights under the Terms of Service or this Privacy Policy; and/or (iv) our business, including helping us better understand and improve our services. These third parties may be located, and use and store your Personal Information, outside of your jurisdiction for these purposes.

Where we permit any third parties to collect and use your Personal Information in accordance with the above paragraph, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement.

You consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this "Sharing of your Personal Information" section.

As we continue to develop our business, we or our affiliate companies may be acquired by a third party or re-organise our group structure. In these circumstances, it may be the case that your Information is transferred within our group and/or transferred to a third party who will continue to operate our services or similar services under either this Privacy Policy or a different privacy policy which will be notified to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your jurisdiction.

You agree that we or our affiliate companies may be required to retain, preserve or disclose your Personal Information: (i) in order to comply with applicable laws or regulations; (ii) in order to comply with a court order, subpoena or other legal process; (iii) in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or (iv) where we believe it is reasonably necessary to comply with applicable laws or regulations. You also agree that we or our affiliate companies may need to disclose your Personal Information in order to enforce the Terms of Service or this Privacy Policy, protect our rights, property or safety, or the rights, property or safety of our affiliate companies or other users of our services.

WHAT CHOICES DO YOU HAVE REGARDING OUR USE OF YOUR PERSONAL INFORMATION?


We may send periodic promotional or informational emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the e-mail. Please note that it may take up some time for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you e-mails about your account or any Services you have requested or received from us.

If you want to request to review, delete, or change the information we have about you; request that we no longer make active use of your information; or if you have additional questions, please send an email to us at feedback@cynking.com with your request and identifying information in the body of the email, including your first name, last name, e-mail address or login name you use to access our Application and Services. We will respond to your email as soon as possible. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have previously allowed us to access your precise geolocation data or receive push notifications through your device, you can stop making precise geolocation available to us or receiving push notifications by visiting your mobile device's settings for the relevant Application or in some cases, through the Application itself. In some instances you can also stop or limit the type of device IDs or cookies you allow (See our Information We Collect Automatically; Device IDs, Cookies, and Other Tracking Technologies above).

A WORD ABOUT SHARED INFORMATION


A number of our services enable Shared Information to be shared publicly with all users of that service and not just your contacts. Our social media services in particular are primarily designed to help you share Shared Information with the world, so Shared Information can be broadly and instantly transmitted and will remain public for as long as you do not delete it (and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us). Please consider carefully what you post and communicate through our services.

COMMUNICATIONS FROM US


Newsletters and other types of communications When you use our services, we may use your Information to send you emails, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.

Service-related announcements

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

A WORD ABOUT SENSITIVE PERSONAL INFORMATION


In some jurisdictions, certain Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as "sensitive" and is subject to stricter regulation than other personal information. Please note that content and information that you input to our services, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others. We urge you to consider whether it is appropriate to communicate sensitive Personal within our services.

You consent to all processing of sensitive Personal Information for the purposes and in the manner described in this Privacy Policy.

Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.

THIRD PARTY SERVICES ON OUR SERVICES


Our services may include, or they may link you to, social media or other services (including websites) provided by a third party. For example:

• you may be able to share content on our services using services provided by third parties. The third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer to enable such third party services to function properly; and • we may (whether in advertisements or otherwise within our services) provide you with links that allow you to access third party services or websites.

These third party social media or other services may be hosted by the relevant third party or us. Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties, are subject to the relevant third party’s own terms of services and privacy policies and not the Terms of Service or this Privacy Policy, so please review their terms carefully.

This Privacy Policy only applies to any Information collected by us, does not apply to any services offered by or information practices of any third parties, and we bear no liability for any third party use of any Information provided by you to them.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION


We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction.

You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy.

We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information.

In some of our services, we will use encryption technology (such as SSL) to protect certain sensitive Information provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control.

Data Retention and deletion


We generally retain your Data for as long as is necessary for the performance of our service and to comply with our legal obligations and then it is deleted or erased based on our internal protocols.

If you no longer want us to use your Data to provide our Service to you, you can request that we erase your Data and close your Account.You may direct such request to our Privacy Officer,We will respond to all requests made to our Privacy Officer under this “Retention of your Personal Information” section within 60 days.If you ask us to remove or delete your Data, we may retain your Data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

Also if you have not been using our Service for a significant period of time, it will be deemed as you no longer need our Service, then we may erase your Data and close your Account, by a prior notice.

However, it is important to note that communications made by you using our services may put your Personal Information in the hands of third parties that we cannot control – for example, if you have previously made your Personal Information public via our services. In some instances, we may not be able to delete your Personal Information and/or Shared Information from our services or systems – in which case we will (where reasonably practicable) let you know why we are unable to do so.

How to contact us If you have any questions or wish to exercise your rights as a data subject established in this privacy notice, please contact us at feedback@cynking.com