SUPER CODE STRIKE – PRIVACY NOTICE

Last Updated: 1 November 2020

1.  INTRODUCTION

Welcome to the Privacy Notice of Super Code Strike, provided by Creatubbles Pte. Ltd., and its subsidiaries and affiliates ("Creatubbles", "we", "us" or "our" in this Privacy Notice).

This Privacy Notice covers the personal information we collect, use and disclose through your use our mobile gaming application Super Code Strike ("App", “SCS App”).

EU Users

There are certain sections of this Privacy Notice that only apply to the use of personal information about users that are located in the European Economic Area or the United Kingdom. The users are referred to in this Privacy Notice as "EU Users".

Updates to this Privacy Notice

You can tell when this Privacy Notice was last updated by looking at the date at the top of the Privacy Notice. If we make changes to this Privacy Notice, we will post the changes here.

If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how we use personal information, we will notify you by way of a prominent posting on our App, prior to the change becoming effective. If you have set up a user account with us, we may also notify you about material changes to this Privacy Notice by e-mail (sent to the e-mail address provided in your account), or as otherwise required or permitted by applicable law. Any changes to this Privacy Notice will become effective upon posting of the revised Privacy Notice. As such, we encourage you to review this website from time to time for the latest information on our privacy practices.

Please note that when you use our APP, we will collect, use AND DISCLOSE YOUR personal information as described in this PRIVACY NOTICE. If you have questions, comments, or suggestions, you can always contact us using any of the ways described in the privacy@creatubbles.com.

2.  PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

We collect personal information from you in accordance with this Privacy Notice any time you contact us, interact with us, create a user account, and while you play with and otherwise interact with the SCS App.

Please be aware that if you do not provide us with personal information that we need, we will not be able to provide certain aspects of the App. For example, we require your mobile or other device ID to operate the App. Or, we require a first name, or username to create your user profile. If you refuse to provide us with essential information, we will not be able to create and manage your user profile, or operate the App on your device. We will let you know when we need personal information from you and the consequences of failing to provide us with that personal information.

PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

CREATING A USER ACCOUNT (13+)

When you create a user account, we collect the following personal information:
 

  • nickname

  • email address

  • age

 

CONTACTING US

When you contact us by email, text, chat, phone or via social media we will collect the information you provide to us, which may include your name, contact details and the contents of your messages, queries, feedback or complaints.

USING WEBSITE OR APP

When you download, visit and use our App, we automatically collect technical information. This section tells you more about the technical information we collect and how we collect it.

Device information Personal Information Collected Automatically

We collect your mobile device ID, operating system, date/time stamp, and/ or clickstream data.

Analytics

We use analytic software, such as Google Analytics and others, to help us to better understand the functionality of our software or App on your device. These software tools record technical information including about your device together with usage information such as how often you use our App, which features you use or don't use in the App, aggregated usage, performance data, where the App was downloaded.

Push Notifications

To ensure you receive proper notifications, we will also need to collect certain personal information about your device such as operating system and user identification information. For example, we require this data to send a push notification to authenticate a user and obtain consent of the parent / legal guardian.

If you change your mind about receiving push notifications from the App, adjust the settings of your mobile device to turn to stop transmission of push notifications at any time.

USER CHAT

The App may allow you to communicate with other users. When you chat with other users, we collect the user ID, as well as the date and time of the chat. We do not record the actual conversation of the chats. We only use this information to provide you with the chat feature and for no other purpose.

 

NON-PERSONAL INFORMATION

We may aggregate, anonymize, pseudonymize, de-identify or aggregate personal information to create non-personal information.

We may use non-personal information for any and all purposes, and we keep it for as long as we have a business need to do so.

 

3.  HOW WE USE PERSONAL INFORMATION

We use personal information for a number of purposes relating to (i) creating your user account and authenticating your ID, (ii) providing you with the SCS App, and (iii) responding to communications.

HOW WE USE PERSONAL INFORMATION

We use the personal information we collect in order to:
 

  • provide you with our App, such as creating your account and allowing you to play the App, providing any requested optional extras and offers or other benefits

  • diagnose problems, analyze trends, and assess our performances

  • improve our operations of the App

  • research and develop new features and products for our App and other services

  • enable third-party applications and features, for example, to allow our authentication provider

  • respond to legally binding requests from law enforcement, regulatory authorities or other third parties

  • defend, protect or enforce our rights or applicable terms of use

  • help us diagnose problems with our main computers and systems

  • for IT system administration

  • report aggregated information to our business partners

  • audit the use of our App

  • enforce compliance with our Terms of Use and to protect our App, users or others

  • analyze trends in the aggregate and administer the App

  • respond to messages, queries, feedback or complaints

  • provide customer / user service functions

  • comply with any legal obligation on us (for example, making any required notification of the incident to appropriate authorities); and

  • comply with applicable law.

 

IN-APP TARGETED MARKETING

We do not use personal information we collect for the purpose of in-App targeted marketing. The App may promote a new feature, or may provide opportunities for users to enhance their App-experience with features provided by a partner (for example, a new skin); however, any such marketing is provided to all users.

 

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EU/UK)

Under applicable data protection law in the European Economic Area and the United Kingdom, there are a number of legal grounds that permit us to use the personal information of EU Users for the purposes stated within this Privacy Notice.

The legal grounds that apply to our use of the personal information of EU Users are:
 

  • that you provided your consent to us using your personal information for that purpose (e.g. to provide you with the App)

  • that the processing is necessary for the purposes of our legitimate interests, and we have balanced these against your rights and interests; and

  • where we need to comply with a legal obligation (for example, responding to government or law enforcement information requests).
     

Our legitimate interests for using the personal information of EU Users are:
 

  • to ensure effective administration and management of your relationship with us.

  • to understand how our users use our App

  • to carry out research, development, and analysis on what services or products our customers want or how they would like to use or improve and develop our Services, products features and to develop new Services, products, and features;

  • to understand how our users use our App and identify any issues in how the App is used and how we can improve the App’s functionality

  • to understand and respond to user feedback

  • to prevent, detect, or investigate unauthorized use of our App and systems and/or abuse or mistreatment of our employees, other users and to protect against those risks and ensure we comply with the law and our policies; and

  • to enforce our legal rights.

4.  HOW WE SHARE PERSONAL INFORMATION

We share personal information with our third-party service providers so that we are able to provide you with the SCS App, to provide customer assistance, as well as to authenticate your identity and complete fraud checks, and support our IT infrastructure.

WHO WE SHARE PERSONAL INFORMATION WITH AND WHY

We may also share personal information with third parties in the event of a merger or acquisition, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. To the extent that local laws require it, we will provide you notice on our websites or via e-mail of our intent to transfer personal information to a third party for this purpose.

In addition, we will share personal information with organizations if we believe in good faith that the disclosure is necessary in order to meet any applicable legal, regulatory or other enforceable governmental or regulatory request or order, detect, prevent or otherwise address fraud, security or technical issues and to protect against harm to the rights, property or safety of us or our group as required/permitted by applicable law.

We may share non-personal information that does not identify an individual in a aggregated/anonymized form, with our third party service providers and partners as reasonably necessary to meet our business needs.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

In operating our business and providing the App, your information will be stored in Canada and the United States.

EU Users – basis of international transfers

For EU Users, your information may be stored in the EU or Canada. Some of our service providers may process information in areas that are located outside the European Economic Area (or, for EU Users located in the United Kingdom, countries located outside the United Kingdom or the European Economic Area).

 

Adequacy of data protection is ensured by standard data protection clauses that we have in place with the relevant recipient. A copy of these standard data protection clauses may be downloaded on the European Commission’s website or requested via our Data Protection Officer. Alternatively, these transfers are made because they are necessary for the performance of a contract to which you will be a party, or for pre-contractual measures.

 

5.  HOW LONG WE KEEP PERSONAL INFORMATION

We keep personal information for no longer than is reasonably necessary or required by law. How long we keep personal information depends on the type of personal information and the purpose(s) for which we collected it.

We have set out how long we will typically keep certain types of personal information in common scenarios below:

6.  HOW WE PROTECT PERSONAL INFORMATION

The security of personal information is important to us. We take reasonable steps to make sure personal information is protected from loss and unauthorized use, access, disclosure, alteration, destruction. Firewalls and encryption are used to protect your more sensitive personal information. You are responsible for keeping your User account safe. If you suspect unauthorized use or security breach of your personal information, you must notify our us as soon as possible

 

7.  THIRD PARTY WEBSITES

Our App may include links to and from the websites of our affiliates and business partners, including social media platforms. We do not control how personal information is collected or used on these websites or social media platforms, so please review the privacy policy of any website or platform you visit as a result of following any links to or from the websites of our affiliates and business partners.

 

8.  CHILDREN’S PRIVACY

The App is only for users who are 13 years of age or older. Do not use this App if you are under 13. We do not knowingly collect information of children.

 

9.  DATA SUBJECT RIGHTS; CONTACT US

If you have questions, comments, or suggestions, you can always contact us. For your protection, we may need to verify your identity before we assist with your request by verifying that you can provide us with information about you that we have previously collected.

 

USER OPTIONS

The choices available to you vary by location, as explained in greater detail below.

CANADA AND UNITED STATES

Access to your information

You have the right to request access to the personal information that we collect, use and disclose about you. In addition, you have the right to request to have certain information corrected and / or updated.

To submit a request or designate an authorized agent to make a request, please email privacy@creatubbles.com.

Deleting your information

You have the right to request that we delete your personal information, subject to some exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information, unless an exception applies.

To submit a request, please email privacy@creatubbles.com.

Want to close your account or otherwise opt-out of Creatubbles collecting, using or disclosing your personal information? We will be sorry to see you go. Please email privacy@creatubbles.com.

Your California Privacy Rights

We do not share your personal information with third parties for their own direct marketing purposes. We do not sell personal information.

To learn more about the categories of personal information we collect, how we collect it, the purpose of the collection, and with whom we share the information, please see the chart below.

EUROPEAN UNION

EU Users may have – in accordance with applicable EU/UK data protection laws applicable in the European Economic Area and the United Kingdom – the following rights when it comes to our handling of your personal information:

  • Right of access – you may have the right to request a copy of the personal information we have about you and to request supporting information explaining how the personal information is used;

  • Right of rectification – you may have the right to request that we rectify inaccurate personal information about you;

  • Right of erasure – you may have the right to request that we erase personal information about you;

  • Right to restrict processing – in some situations, you may have the right to request that we do not use the personal information you have provided (for example, if you believe it to be inaccurate);

  • Right to data portability – you may have the right to receive your personal information in a structured, commonly used and machine-readable format and to transmit such information to another controller;

  • Right to withdraw consent – where we process your personal information based on consent (including direct marketing consents), you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal we may continue to use your personal information as permitted or required by law;

  • Right to object – where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your personal information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.

 

To exercise any of these rights, please email privacy@creatubbles.com.

10.  Contact Us

You can also get in touch with our Data Protection Officer at privacy@creatubbles.com if you should have any concerns about how we process your personal information, or any questions about this Privacy Notice.