PikPok

PIKPOK PRIVACY POLICY NOTICE

 Effective Date: September 1, 2023

(Last Updated September 1, 2023)

Previous policy

We respect your privacy rights and protect the personal information collected, stored and used in connection with our products, services and websites. Your privacy is important to us. To further this commitment, we have adopted this Privacy Policy to guide you on how we collect, store, and use the information you may provide to us, and to inform you of your rights under applicable law. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

 

1. Protecting Your Privacy

This Privacy Policy applies to any PikPok game, website, application, service or tool (collectively, our “Services”).

We are committed to protecting the privacy of all people who use our Services. Being a New Zealand company, we comply with New Zealand’s Privacy Act 2020 (“Privacy Act”) and follow the privacy principles that are a part of the Privacy Act. Additionally, we seek to comply with relevant laws from the United States of America, including: the federal Children’s Online Privacy Protection Act (“COPPA”), the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 (“CAN-SPAM”), which covers the transmission of commercial email messages with the primary purpose of advertising or promoting a product. For Individuals located in the EU, we also seek to follow the EU General Data Protection Regulation (“GDPR”). For purposes of this Privacy Policy and GDPR, PikPok is the data Controller with regard to any data we collect from you, unless otherwise specified. For individuals located in Brazil, we also seek to follow the Lei Geral de Proteção de Dados (commonly referred to as the “LGPD”). For individuals located in Colombia, we also seek to follow the Ley de Protección de Datos Personales (commonly referred to as “Law 1581 of 2012”), Decree 1377 of 2013, and other related regulations.

Disclosure to Residents of the US states: In our efforts to comply with applicable laws, we ask and advise that residents review the Disclosure at Section 12 of this Privacy Policy. Although we do not sell user data, we will provide notice if at any time those circumstances change.

Disclosure to Residents of Brazil: The LGPD grants residents of Brazil certain rights about the processing of their personal information and we ask and advise that residents of Brazil review the Additional Rights at Section 9 of this Privacy Policy.

Disclosure to Residents of Colombia: Law 1581 of 2012 and Decree 1377 of 2013 grant residents of Colombia certain rights regarding the processing of their personal information, and we ask and advise that residents of Colombia review the Additional Rights Section 9 of this Privacy Policy.

Prodigy Design Limited, trading as PikPok (“PikPok”) provides interactive software products (“Games”) via online services such as Apple iOS App Store, Apple iOS TV App Store, Google Play Store, Amazon App Store, Amazon Underground App Store, Apple Mac App Store, PlayStation Network, Oculus Rift, Samsung App Store, Steam, Windows PC Store, Windows Phone Store, Xbox Live Arcade, Facebook, Bandcamp, and Zazzle.

We own and operate various websites and their subdomains including but not limited to www.pikpok.com (our “Sites”) to provide access to information about PikPok, the Games and products, message boards, head to head match play or provide technical support to PikPok users (collectively, our “Content”).

We are providing this Privacy Policy solely to inform you of our practices and procedures concerning our collection, use and processing of your data, as well as your rights with regard to that data. This Privacy Policy is not a contract, and your acceptance and approval are only required where we request your consent to collect certain types of data. However, you are required to comply at all times with the Terms of Use of our Services (located at: http://www.pikpok.com/terms-of-use), and any violation thereof or abuse of our Services, including violations that may impact your privacy rights or the privacy rights of other users, may lead to the suspension or termination of your access to our Services.

 

2. What Personal Information Do We Collect?

Our Sites

While you are browsing our Sites, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring website addresses may be logged automatically. We may use this information to monitor and analyze your use of our Services. In addition, we may ask you to submit and we may process data that is personal to you, including but not limited to your name, profile photo, gender, age or birthday, links to your profiles on social networking websites and other third party sites, usernames and email and postal addresses. We may use this information to create a user profile customized to you. We may use your email address to contact you about your experience with our Sites and to notify you about PikPok news and promotions. Your gender and birthday may be used to analyze user trends and target certain promotions to you. Your postal address may be used if we have merchandise or other physical promotional materials to send to you.

Forums

You may, from time to time, have the ability to post content to a blog, message board, chat room or within our Services or other public forums such as our Facebook page (“Forums”). You should be aware that any visitor to the Forums may read anything you post or any information you voluntarily make available on the Forums. For example, any information that you post to a Forum, including your username or other account profile information, will be publicly displayed to all users and viewers of that Forum. Please be aware that we cannot secure any information or statements you personally make available on our public Forums, and you provide such information at your own risk. We do not author, edit, endorse, or monitor any Forum. However, we can remove information you have posted if you contact us at privacysupport@pikpok.com. In the alternative, and if the feature is available on the Forum in question, you may also have the option to delete your posts directly. Although we cannot ensure that historical versions, such as cached versions of your post made available through search engines, will not be shared or stored by third parties, upon your request we will do our best to remove such posts from our own application and pages.

iOS and Android Platforms

When you use any of our Services on a mobile platform, we may collect and record certain information such as your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address (if you have connected to Facebook or you Google Account), and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends. In addition, we create a unique user ID to track your use of our Services. This unique user ID is stored in connection with your profile information to track the Games you are playing, so that we can always make the Games you play available to you.

Facebook Connect, Apple’s Game Center, and your Google Account

You may connect your PikPok user account to your accounts on the following social networking services (“SNS”): Facebook, Apple’s Game Center, and your Google Account. We may collect and record information through an SNS in accordance with the policies and terms of that SNS. The information we collect when you connect your PikPok user account to an SNS may include: (1) your name, (2) your SNS user identification number and/or user name, (3) profile picture or its URL, and (4) the SNS user identification numbers for your contacts who are also connected to our Games.

If you want us to delete the data we receive from Facebook, Apple’s Game Center, or your Google Account about you, please contact us at privacysupport@pikpok.com

Invite a Friend

PikPok may offer you the opportunity to invite your contacts from an SNS (such as your Facebook friends) so that those contacts can be located in our Games and/or you can invite them to join you in playing our Games. Such contact information will be used only for the purpose of sending communications to the addressee. You or the third party may contact us at privacysupport@pikpok.com to request the removal of this information from our database to the extent we store any of this information.

Customer Service

We may collect your name, email addresses, postal addresses, and/or telephone calls with names and numbers to return calls when you contact our customer service group. We use that information to contact you about your experience with our Services and notify you about PikPok news and promotions.

Game Data Collection

Whenever you play our Games, we collect data about your interactions with the Game and with the other users inside the Game via server log files. We use this information to help improve your Game experience and monitor the performance of the Game.

Other Collection

We may also acquire information from you through your access and participation in message boards on the Services, your participation in surveys regarding the Services, or your participation in a sweepstakes or contest through the Services.

Cookies

A cookie is a small text file that we transfer to your computer and/or device, to identify a user’s computer/device and to “remember” things about your visit to our Sites and use of our Services, such as your preferences or a username and password. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our Services (e.g., improving a user interface or method of input based on how our end users use our Services), tailoring recommendations to your interests (e.g., personalized ads you want to see, personalized interface or Game play), and making the Services easier to use (e.g., including accessibility options or making certain features more prominent). You can disable cookies at any time, although by doing so, you may not be able to access or use all of the features of our Services.

We may feature advertisements served by third parties that deliver cookies to your computer/device so the Content you access and advertisements you see can be tracked. Since the third party advertising companies associate your computer/device with a number, they will be able to recognize your computer/device each time they send you an advertisement. These advertisers may use information about your use of our Services and third party sites and applications in order to measure advertisement performance and to provide advertisements about goods and services of interest to you. This Privacy Policy does not apply to, and we are not responsible for the data collection practices of these third party advertisers, and we encourage you to review their privacy policies (provided below) to learn more about their use of cookies and other technology.

You may click on the following link: http://www.networkadvertising.org (or such other URL as may be specified by us from time to time) (or such other URL as may be specified by us from time to time) for information on how to opt-out of the use of cookies for the delivery of more relevant advertising.

Third Party Services

Our Services may contain third party tracking tools from our service providers, examples of which include tracking tools from Amazon Pinpoint, Google Analytics, Unity Analytics, Appsflyer and AppSumer. Such third parties may use cookies and other software tools in our Services to enable them to collect and analyze user information on our behalf. We use this information to: assist us in providing player feedback to improve player experiences in our Games and apps, manage crash reports and bug reporting, process payments, and prevent, detect, mitigate and prohibit security breaches and/or fraud. These third parties may have access to information such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geolocation information, and IP address.

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to our Sites or Games, you should consult that website’s privacy policy before providing any personal information.

The service providers that PikPok uses can be found here.

Ad and Offer Networks

We may feature advertising and offers within our Services. The advertisers may collect and use information about you, such as your session activity within our Services, advertising identifier, device identifier, MAC address, IMEI, geolocation information, and IP address. They may use this information to provide advertisements of interest to you.

We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to our Sites or Games, you should consult that website’s privacy policy before providing any personal information.

The advertising partners that PikPok users across its Games can be found here.

In addition, you may see our Games advertised in other services. After clicking on one of these advertisements and installing our Game, you will become a user of our Services. In order to verify the installs, a device identifier may be shared with the advertiser.

Subscribe

We may use the email address you provide to us at www.pikpok.com/subscribe to contact you with newsletters, marketing, or promotional materials. You can easily opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting the Privacy Officer via the information provided in the “Contact Us” section below.

 

3. How Do We Use Your Information?

We use your personal information to provide and improve our Services, provide you with a personalized experience on our Sites, contact you about your account and our Services, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities.

We use the personal information we collect from you for a range of different business purposes and according to different legal bases of processing. The following is a summary of how and according to which legal bases we collect and use your personal information.

We use your personal information to fulfill a contract with you and provide you with our Services, to comply with our legal obligations, protect your vital interest, or as may be required for the public good. This includes to:

  • Provide and deliver products and services at your request;
  • Create game accounts that allow users to play our Games;
  • Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • Prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities; and
  • Enforce our Terms of Service or other policies, and to comply with this Privacy Policy, our internal data protection processes, and applicable laws.

We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests, and we only collect the minimal information necessary to pursue such legitimate interests. This includes to:

  • Operate and improve our Games and Sites;
  • Understand you and your preferences to enhance your experience and enjoyment using our Games and Sites;
  • Communicate with you about promotions, rewards, upcoming events, and other news about products and Services offered by PikPok and our selected partners;
  • Identify and suggest connections with other PikPok users;
  • Respond to your comments and questions and provide customer service;
  • Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better Services;
  • Enable third parties to collect device information and personal information solely to deliver contextual or non-personalised advertising; and
  • Internally measure our marketing campaign performance.
  • Internally measure our social media and community engagement performance

With your consent, we may use your personal information to:

  • Provide personalised or interest-based advertising.

We actively minimize the amount of data we collect about you in connection with our legitimate interests, and only collect the minimal data necessary to provide our Services consistent with our legitimate interests. By way of example, our Games are generally free-to-play and supported substantially through in-game advertisements. We only collect the minimal amount of information about your device as may be necessary to deliver such advertisements, such as your device information, IP address, the country where you are located, and other such information necessary to display non-personalised ads via our third party providers. Where additional information is collected for the purpose of providing personalised ads, we require your consent before we will collect or share that information.

 

4. Who Do We Share Your Information With?

We do not share your personal information except as approved with your consent or as described below. We do not sell or rent your personally identifiable information to any third party, although non-personally identifiable information may be used to assist advertisers in targeting their services to specific user demographics. For example, we may provide third party advertisers with the aggregate number of males of a certain age in a specific country who are playing one of our Games.

  • We share statistics of each user’s activities and data within reports that are used internally and externally by our publishing and distribution partners to analyze our Games, their features and performance.
  • With your consent, for example, when you agree to us sharing your information with third parties and advertising networks for their own marketing purposes subject to their separate privacy policies.
  • We may release your information as permitted by law or when we believe that release is appropriate to comply with applicable law; enforce or apply our rights; or protect the rights, property, or safety of use or our uses or others. This includes exchanging information with other companies and organizations for fraud protection.
  • We may share your information in connection with any merger, sale of our assets, or financing or acquisition of all or a portion of our business to another company.
  • We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.

 

5. How Long Do We Keep Your Personal Information?

We retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our Terms of Use, end user license agreements, and other contracts in place with third parties, including but not limited to our third party service providers and independent data controllers. Upon your request to remove your data, we will do our best to remove such data immediately, and in no event will we retain any data requested for removal more than thirty (30) business days after the date of the request.

 

6. Is My Information Secure?

The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect your information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

All gameplay services provided to you by PikPok are hosted using various Amazon Web Services (AWS). AWS is a global leader in cloud technology and has robust data protection, privacy policies and processes in place. For more information, see https://aws.amazon.com/security/ and https://aws.amazon.com/compliance/data-privacy-faq/.

 

7. Does My Information Go Across Borders?

We use third party servers in the United States to host some or all of our Games and we use our own servers at our facilities in New Zealand to store information and archives. Therefore, your personal information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information. Our third parties have executed or provided to us adequate safeguards in the form of our standard Data Protection Addendum to our agreements with those third parties, which we can provide to you upon your request by contacting privacysupport@pikpok.com.

Where you have the option to withdraw consent to opt out of any collection where your data is transferred across borders, you may do so. The transfer of such data is typically for the purpose of providing our Services to you, as specified above. Consequently, any request to delete or modify such personal information may result in the termination or interruption of our Services with respect to your usage of such Services.

 

8. Is Sensitive Information Collected?

We do not ask you to provide any “sensitive information” as a requirement to use our Sites or any of our Games. “Sensitive Information” means any personal information related to your health or sex life, genetic or biometric data, race, ethnicity, political views, religion, professional status, philosophical view, and trade or union affiliation. Sensitive Information that you disclose to “everyone” on a discussion forum or through a social networking site in connection with a Game may be collected and held by us in accordance with this Privacy Policy. We do not use or share Sensitive Information with third parties. Please contact us if you have any questions or concerns about any Sensitive Information that you may have disclosed to us or to other users during your use of a Game that we may have collected. We do collect non-personally identifiable information regarding Game usage, including but not limited to, the top country, city and language by aggregate usage as provided by the social networking sites.

 

9. Your rights to access, control, and correct your personal information

You have the right to see what personally identifiable information we hold about you if you request it. If your request is particularly complex or requires detailed searching of our records, there may be a cost to you in order for us to provide you with this information. We will aim to respond to any requests within thirty (30) days of receipt.

Accessing and Controlling your Information

If you wish to modify the information you have provided, or obtain a copy of your information, or if you wish to cancel your account or withdraw your consent to some or all of the personal information collected that requires your consent, there are two methods that we provide.

Option 1 (Recommended): In select Games from mid-2018, you can access and control your personal information from the Settings screen of the Game, by tapping support and going to the privacy section.

We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. We may not be able to delete certain information you have provided to us directly through our Services or on our Forum, especially information you make publicly available.

Option 2: You may send an email to privacysupport@pikpok.com. Place “[Delete/Change/Access/Request a Copy of] My Data” in the subject line (choose the word that best suits your request) and include:

  • Your PikPokPlus (User) ID (per Game). You can find this in the settings screen of most of our Games.
  • The name of the PikPok Game(s) or Site(s) you are using.
  • Your first name, last name, email address which are used for communication purposes and keeping accurate recordings of processing.
  • Identify the information you would like to delete, change, or access.
  • If you are requesting a copy of your information, the file format you prefer.

Controlling Personalised Ads

You have the right to withdraw consent at any time for ongoing data collection that requires your consent, such as use in personalized ads. To reset or limit any personal data collected for the purposes of serving personalised ads in our Games:

  • For iOS devices with IOS14 and above
    • You can enable or disable tracking of personal data globally in Settings->Privacy->Allow Apps to Request to Track
    • You can Opt in to apps allowing them to track on an individual basis if you do not set the global option.
  • For iOS device with older versions of iOS
    • You can reset your advertising identifier in Settings->Privacy->Advertising->Reset Advertising Identifier.
    • Or limit ad tracking by enabling the Limit Ad Tracking option.
    • For more information see: https://support.apple.com/en-nz/HT202074.
  • For Android devices
    • Open Google Settings on your Android device by tapping on menu and then on Google Settings once all apps are displayed on the screen.
    • Locate and tap on the Ads menu under Services.
    • Tap on “Reset advertising ID” on the new page to prevent further tracking.
    • Tap the On/Off slider to Opt out of Ads Personalization
  • Some ad networks used in our Games and Sites request your consent before collecting any personal data for the purposes of serving personalised ads. These typically include in-ad controls to allow you to adjust your privacy settings.

    For Facebook ads, you can control your personalised ad settings in the privacy settings here.

    Information We Receive From a Social Networking Service (SNS) Where You Play Our Games

    To manage the information we receive about you from an SNS where you play our Games, you will need to follow the instructions at that particular SNS for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here. The privacy management tools for you Google Account can be found here. You can also manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions for each application.

    Once we receive your information from an SNS, that information is stored and used by us in accordance with this Privacy Policy, and you may access and update that information as described below. Game or other accounts created with us are considered active until we receive a user request to delete or deactivate them.

    Additional Rights

    In addition to the rights described above, you also have the right to object to any collection practice where we have relied on a legitimate interest as described in detail herein. You may submit any such objection to privacysupport@pikpok.com. We will do our best to respond and take measures to mediate any such objection within thirty (30) days.

    If you are dissatisfied in any way with our collection of your data, or if you have questions concerning this Privacy Policy, please contact us via the information provided in the “Contact Us” section below.

    Individuals Located in the EU: If we are unable to resolve any dispute with you, and you reside in an EU Member State, you may contact the regulatory authority in your Member State responsible for administering rights with regard to GDPR. You may also contact the reporting authority in the United Kingdom, the Information Commissioner’s Office, by following this link: https://ico.org.uk/.

    Individuals Located in Brazil: The LGPD grants you certain rights about the processing of your personal information. In addition to any applicable rights mentioned above, eligible residents of Brazil also have the right: (i) to the anonymization, blocking, or elimination of your personal information, if you believe we are processing your personal information in an unnecessary, exceeding or non-compliant manner with the LGPD; (ii) to request the portability of your personal information; (iii) to request information about the entities with which we have shared your personal information; and (iv) to request information about the possibility and consequences of denying consent. While our processing of personal information generally does not include automated decision-making, you are also entitled to a review of our decisions that are made solely based on automated processing of personal information that affect your interests. Notwithstanding any other references to the contrary within this Privacy Policy, in accordance with the LGPD, we will respond to your request within fifteen (15) days after receipt and we will provide any requested information free of charge to you. You may also file a complaint with the National Data Protection Authority in Brazil, the Autoridade Nacional de Proteção de Dados (“ANPD”) for alleged violations of the LGPD, in addition to or alternatively to seeking judicial redress.

    Individuals located in Colombia: Law 1581 of 2012 and Decree 1377 of 2013 grant you certain rights regarding the processing of your personal information. In addition to any applicable rights mentioned above, eligible residents of Colombia also have the right to (i) request proof of authorization, (ii) File complaints before the Colombian Superintendence of Industry and Commerce for violations of the provisions of the law, (iii) request information and/or file a claim if you consider that the information contained in a database must be corrected, updated or deleted, or when you notice an alleged breach of any of the duties contained in this law. Notwithstanding any other references to the contrary within this Privacy Policy, in accordance with Law 1581 of 2012, we will respond to your request within fifteen (15) days after receipt, and we will provide any requested information free of charge to you. When it is not possible to attend the claim within such terms, your party will be informed of the reasons for the delay and the date on which the claim will be attended. You may also file a complaint with the Colombian Superintendence of Industry and Commerce, the Superintendencia de Industria y Comercio (“SIC”), for alleged violations of Law 1581 of 2012 and other related regulations.

    Individuals located in the United States of America: For information and additional rights that may be available to individuals located in certain U.S. states, please review the “Additional Information for Residents of California and Certain Other U.S. States” at Section 12 of this Privacy Policy.

 

10. What Happens When I Remove A Game or Unsubscribe From A Newsletter?

You have the ability to opt-out of: receiving information and marketing emails from us; publishing your recent Game activity to your SNS page; bookmarking or displaying the Game page to others, and of course the ability to delete our Game and rescind any permissions required to operate such Game, at any time.

It is our responsibility to keep accurate, complete and up-to-date records, so any changes you make in a Game regarding your personal information will go into effect as quickly as technically possible. We reserve the right to retain the non-personally identifiable data collected during your use of the Game.

We have the right, pursuant to our Terms of Use, to delete messages, content and accounts in whole or in part, at our discretion, that we find offensive to the general public, uses profanity, causes complaints from other users, is not suitable for a general audience or infringes the intellectual property rights of any third party. For example, talk of drugs, alcohol, violence, strong language, gambling, crude humor, sexual themes or those suggestive in nature is prohibited.

 

11. Children’s Privacy

We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our Services. Some of the features on our Sites and Games are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features.

When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:

  • Notifying parents or guardians about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;
  • In accordance with applicable law, obtaining consent from a parent or guardian for the collection of personal information from their children, or for sending information about our products and Services directly to their children; and
  • Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity.

If you are a parent or guardian and wish to review or change the information we may have about your child, email us at privacysupport@pikpok.com.

 

12. Additional Information for Residents of California and Certain Other U.S. States

Under the laws of California and certain other U.S. states, including Colorado, Connecticut, Utah, and Virginia, the residents of those U.S. states who have an established business relationship with us may choose to opt out of our disclosure of personal information about them to third parties for direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for their direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email privacyofficer@pikpok.com.

The California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) requires operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the websites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and sites has not yet been widely adopted. Currently, our computer system does not support, and cannot act on DNT signal headers that we may receive; accordingly, the choices that we provide you concerning our collection and use of personally identifiable information will continue to operate as described in this Policy. For information about Do Not Track, please visit: www.allaboutdnt.org

How Do We Use Your Information?

In addition to the details provided in 3. How Do We Use Your Information?, residents of California, Colorado, Connecticut, Colorado, Utah, and Virginia can refer to the table below, which identifies the categories of personal information we collect and provides examples of personal information in such categories.

Category Data Collected Reason for Collection Has Information been “Sold” to 3rd Party In the preceding twelve (12) months?
Identifiers PikPokPlus ID (Online identifier) To operate a user account on PikPok’s servers for the respective Game No
Internet protocol address (truncated) Analytics (by coarse location), fraud detection, personalised ads, marketing campaign performance measurement Yes (personalised ads)
Advertising identifier Personalised ads, marketing campaign performance measurement Yes (personalised ads)
MAC address Personalised ads, marketing campaign performance measurement Yes (personalised ads)
Email Address Customer support, opt in user surveys No
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). None Collected n/a No
Protected classification characteristics under California or federal law. None Collected n/a No
Commercial information. Game install details, In App Purchase history Analytics, personalised ads, marketing campaign performance measurement, customer support and fraud detection Yes (personalised ads)
Biometric information. None Collected n/a No
Internet or other similar network activity. Game install details, In App Purchase history, Session events Analytics No
Advertising events (clicks, ad engagement) Personalised ads Yes
Geolocation data. Coarse location (inferred from Internet truncated protocol address) Analytics, fraud detection. No
Sensory data. None Collected n/a No
Professional or employment-related information. None Collected n/a No
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). None Collected n/a No
Inferences drawn from other personal information. None Collected n/a No

We may obtain the categories of personal information listed above from the following sources:

  • Directly from our users. For example, from users who engage us for customer support or to provide customer feedback.
  • Indirectly from our users. For example, through information we collect from our users in the course of providing customer support to them.
  • Directly and indirectly from activity on our Sites or in our Games. For example, from APIs and cookies (described above) embedded in our Sites or Games to measure Game metrics and progress, play time per level, and other information related to improving our Services.
  • From third-parties that interact with us in connection with the Services we perform. For example, from third party analytics or anti-cheat providers, or to ad mediators for the purpose of providing personalized advertising and marketing customized to you.

All such personal information is used as otherwise described in this Privacy Policy.

Sharing 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 twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Identifiers, commercial information, internet or other similar network activity, and geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • 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.
  • Our vendors.

Your Rights To Access, And Control Your Personal Information

  • Depending on your location in the U.S., applicable state law may provide you with some or all of the data rights listed below. However, such rights are not absolute and may be subject to certain exceptions.
  • Request access to or a copy of your personal information.
  • Request deletion of your personal information.
  • Request correction or modification of your personal information.
  • Be informed about the personal information we collect and/or process about you, the sources of personal information, and the third parties with whom information was shared or sold and for what purposes.
  • Withdraw consent, if processing is based on consent.
  • Opt-out of the sale or sharing of your personal information (including targeted advertising).
  • Opt-in/out of financial incentives.
  • Limit the use and disclosure of your sensitive personal information.

Exercising Your Rights

To opt out of the sale or sharing of personal information, please follow the instructions in Controlling Personalised Ads.

We recommend submitting data access requests using methods described in 9. Your rights to access, control, and correct your personal information.

You can also submit requests to exercise your data rights through any of the methods in Section 14 (Contact Us). Once you contact us to exercise any of your rights, we will first acknowledge receipt of your request within 10 business days of receipt of your request. Note we may ask for some confirmation details before actioning any request. Please keep in mind that limiting use of, or deleting, your personal information may impact features and uses that rely on that information.[EC1]

Verification; Authorized Agents

We may need to verify your identity in order to process your request to exercise your data rights, and we reserve the right to confirm your identity and residency, and in our discretion, deny your request if we are unable to verify your identity or residency. You may authorize someone to make a request to exercise your rights on your behalf (an authorized agent). Authorized agents will need to demonstrate to us that you have authorized them to act on your behalf, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity and/or verify the authenticity of the request directly with you.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. [EC2] The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Appeals; Non-Discrimination

In certain U.S. states, you may have the right to appeal our decision regarding a request related to the data rights described above. If you wish to appeal a decision, please contact us through any of the methods in Section 14 (Contact Us). We will not discriminate against you for exercising any of your data rights. Unless permitted by the applicable law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

Separate from the CCPA, California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our Sites who are California residents to annually request, free of charge, information regarding our disclosure of personal information (if any) to third parties for direct marketing purposes during the immediately preceding calendar year. While we do not share personal information collected online with third parties for their own direct marketing purposes and will not do so unless you agree to such disclosure, California residents may make such a request, by sending an email to privacysupport@pikpok.com or using the information provided in the “Contact Us” section below. In your request, please identify yourself as a California resident and provide sufficient information so we can take appropriate action, such as your name, email address or any additional information required.

 

13. Changes to the Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy, we will post those changes on this page and update the date at the top of the page. We will also notify changes on various channels we might have to reach you including push notifications (if available), our Facebook page, our Company Website, or via notification directly in our apps. The changes will be effective when posted. Please check this page on a regular basis so that you remain aware of what information we collect and how we use it.

 

14. Contacting Us

For enquiries regarding this Privacy Policy and personal information, please contact:

By Email:
Contact Us or privacyofficer@pikpok.com

By Mail:
Prodigy Design Limited
Privacy Officer
Level 7, Willbank House
57 Willis Street
PO Box 6203
Marion Square
Wellington
New Zealand

By Phone:
+64 (4) 978 9400