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”).
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.
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 email@example.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.
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.
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 firstname.lastname@example.org
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 email@example.com to request the removal of this information from our database to the extent we store any of this information.
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.
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.
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.
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.
The service providers that PikPok uses can be found here.
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.
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.
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.
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:
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:
With your consent, we may use your personal information to:
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.
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.
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/.
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.
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.
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 firstname.lastname@example.org. Place “[Delete/Change/Access/Request a Copy of] My Data” in the subject line (choose the word that best suits your request) and include:
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:
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.
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.
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 email@example.com. We will do our best to respond and take measures to mediate any such objection within thirty (30) days.
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/.
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 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:
If you are a parent or guardian and wish to review or change the information we may have about your child, email us at firstname.lastname@example.org.
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 email@example.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
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:
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:
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]
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.
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.
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:
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 firstname.lastname@example.org 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.
Prodigy Design Limited
Level 7, Willbank House
57 Willis Street
PO Box 6203
+64 (4) 978 9400