NOTICE OF
UPDATE TO PRIVACY POLICY
In order to
provide better service to our users and to increase the level of transparency
around our privacy practices, we have made some updates to our policy including
changes describing what data are collected through the use of our applications.
Should you have
any questions regarding these updates, please email us at henning@devarai.com
Devarai Privacy
Policy
Last Revised June
4, 2012.
Devarai, GmbH, its
subsidiaries and affiliated companies (“Devarai” or “we”) provide this Privacy
Policy to inform you of our policies and procedures regarding the collection,
use and disclosure of information we receive from users of (i) the website
located at http://www.Devarai.com (the “Site”), including any
services, features and content accessible or downloadable from the Site, and
(ii) any other Devarai application, service or product licensed, downloaded or
otherwise accessed by such users through third party websites or sources ((i)
and (ii) collectively, the “Service”).
Acceptance and
Consent:
By registering for
a user account or using our apps that enables you to post to the Forums (the “Account”), and/or
using the Service, you agree to the terms and conditions of this Privacy
Policy, and you consent to the collection, use and disclosure of your
information by Devarai in accordance with the terms and conditions of this
Privacy Policy. If you do not agree to the terms and conditions of this Privacy
Policy, please do not provide us with any information and do not use the
Service.
Changes to the
Privacy Policy:
Devarai reserves
the right, in its sole discretion, to change or modify this Privacy Policy at
any time by posting the changed or modified version of the Privacy Policy on
the Site. Any such changes or modifications will be effective immediately upon
posting. If we make any changes to this Privacy Policy, we will change the Last
Revised date above.
Information
Collection and Use:
Our primary goals
in collecting and using information are to provide and improve the Service, to
administer and assist you in administering your Account on the Service, and to
provide you with a better experience with the Service. We
store and process information in the United States.
Personal
Information and Non-Personal Information
Devarai may
collect personal and non-personal information from you when you use the
Service. Personal information is information that specifically identifies an
individual, including, but not limited to, an individual’s name, phone number,
credit card or other billing information, email address and home address. This
Privacy Policy in no way limits or restricts our collection of aggregate or
anonymous information. In this Privacy Policy, we refer to all information
collected from or about you, including personal information and non-personal
information, as “Your Information.”
Use of Account
We may collect
Your Information, including your email address, in connection with your
creation of an Account. You can register for an Account via a Devarai
application. Certain of Your Information, such as your username and other information, may always be publicly visible by other users
of the Forums, including when such users view your Account profile page. Your
email address will not be publicly visible unless you choose to make it visible
in your Account profile page. When you register for an Account or later access
your Account, you may be able to adjust settings and preferences within your
Account to choose whether to share and make publicly visible other pieces of
Your Information, and the Service may display Your Information based on the
settings and preferences you choose. We encourage you to consider carefully
what information to share as part of your Account profile and elsewhere in the
Service, and we recommend that you guard your anonymity and sensitive
information and not use your real name as your username, as that may allow
other users of the Service to identify you. Any information you choose to share
should reflect how much you want other users of the Service to know about you.
You can review and revise your Account profile information at any time.
We may also
request and collect Your Information when you administer or personalize your
Account after registration or otherwise interact with the Service. For example,
we may collect Your Information both when you enter promotions on or in
connection with the Service as well as in connection with your transactions
(such as, but not limited to, donations or the purchase of products) through
the Service or with Devarai’s advertisers. Such transaction-related information
may include payment information, such as information regarding your account
with an online payment service provider, and information about your use of
products and services offered by our advertisers.
Use of
Applications
When you launch
any of our applications, we collect information regarding your device type,
operating system and version, carrier provider, IP address, Media Access
Control (MAC) address, International Equipment Mobile ID (IMEI), whether you
are using a point package, the game version, the device’s geo-location,
language settings, and unique device ID. In addition, we create a unique user
ID to track your use of our Service. This unique user ID is stored in
connection with your Account profile information to enable us to move Your
Information to a new device at your request. In addition, it may be used to
link a character with which you play our games to your username on the Forums.
When you play our games, we also collect information about your play and
interaction with other users and the Service.
We may collect
Your Information, such as your name or email address, from third party websites
or other sources from which you download or access Devarai applications,
services or products that also make up part of the Service.
We use Your
Information to provide the Service, to attempt to provide you with a better experience,
to improve the quality and value of the Service and to analyze and evaluate how
the Service is used. We may also use Your Information to serve you
specifically, for instance, by delivering products or advertisements to you
according to your preferences or restrictions. We may also use Your Information
to contact you with communications such as Devarai newsletters, marketing or
promotional materials and other information that may be of interest to you.
SMS
Notifications & Push Notifications
We receive and
store the information you provide, including your telephone number, when you
sign up to have SMS notifications sent directly to your mobile device. These
messages notify you of in-game activity and may allow you to play the game from
your phone. With your consent we may send push notifications to your mobile
device to provide game updates and other relevant messages.
Communications
Features
You may be able to
take part in certain activities in our applications that give you the
opportunity to communicate or share information with Devarai and other users of
our Service. These include: (a) participating in player forums and message
boards, (b) posting comments to other users' profiles, (c) sending private
messages or invitations to other users, (d) chat with other users, and (e)
posting photos.
We may record and
store archives of these communications. You acknowledge and consent to the
recording and storage of such communications.
Log Data,
Cookies and Web Beacons
When you browse
certain portions of the Service, we may automatically collect and record
standard user information and clickstream data about your visit (through the
use of cookies and otherwise) as part of our analysis of the use of the
Service. For example, when you visit or request a web page from our server, we
may record the IP address of the user’s machine, the time, date and URL of the
request and information about the browser being used, and other information
regarding the visit, such as the pages visited on the Service, the time spent
on each page, any advertisements clicked and any search terms used
(collectively, “Log Data”). Log Data may be aggregated and used to monitor and
analyze use of the Service and to enable us to analyze traffic and trends,
administer and improve the Service, identify and keep track of errors and bugs,
and gather broad demographic information to become more familiar with where
visits to the Service originate, how often the Service is visited and what
parts of the Service are visited most often. We may also share such information
with third party service providers assisting us with the foregoing and with our
advertisers. For example, some of this information may be collected and used so
that when you visit the Service again, it will recognize you and serve
advertisements and other information appropriate to your interests. We also use
this information to verify that visitors to the Service meet the criteria
required to process their requests. We may link Log Data to Your Information
for tracking and analyzing our customers’ use of the Service to help improve
the Service, to tailor the Service to their needs and to enforce the Terms of
Use.
A cookie is a
small data file that we transfer to your computer’s hard drive. Like many
websites, we also use “cookie" technology to collect additional website
usage data, to improve the Service and in some cases to enable you to more
easily log in to your Account. We do not use cookies to collect personal
information. However, we may combine information collected through the use of
cookies we issue with personal information that you provide to us. Devarai may
use both session cookies and persistent cookies to better understand how you
interact with the Service, to monitor aggregate usage by our users and web traffic
routing on the Service, and to improve the Service and our other products and
services. A session cookie enables certain features of the Service and is
deleted from your computer when you disconnect from or leave the Service. A
persistent cookie remains after you close your browser and may be used by your
browser on subsequent visits to the Service. Persistent cookies can be removed
by following your web browser help file directions. Most Internet browsers
automatically accept cookies.
We may feature
advertisements served by third party advertising companies which deliver
cookies to your computer or device so the advertisements you see can be
tracked. These advertisers may use information about your visits to our Service
in order to provide advertisements about goods and services of interest to you.
You can instruct
your web browser, by editing its options, to stop accepting cookies or to
prompt you before accepting a cookie from the websites you visit. If your
browser is set to refuse all cookies, however, some features of the Forums may
not function properly.
We and third party
advertising companies may collect information using Web beacons. Web beacons or
“gifs”, are electronic images that may be used on our Site, in our Service or in
our emails. We use Web beacons to deliver cookies, count visits and to tell if
an email has been opened and acted upon. Advertisers may use web beacons in
connection with our Service in order to collect and use data regarding
advertisement performance and your interests for the purpose of delivering
relevant advertising to you.
Sharing Your
Information
We may share Your
Information with third parties with whom we have a strategic relationship such
as ad networks and analytics providers. The information shared with these third
parties may be used for industry analysis, tracking ad conversions or
demographic profiling.
We may employ
third party companies and individuals to facilitate the Service, to provide the
Service on our behalf, or to assist us in analyzing how the Service is used.
These third parties have access to Your Information only to perform these tasks
on our behalf and may not use Your Information for any other purpose. We may
also provide Your Information to our business partners or other trusted
entities for the purpose of providing you with information on goods or services
we believe will be of interest to you.
We will disclose
any information about you to government or law enforcement officials or private
parties as we, in our sole discretion, believe necessary or appropriate to
respond to claims and legal process (including but not limited to subpoenas),
to protect the property and rights of Devarai or any third party, to protect
the safety of the public or any person, or to prevent or stop activity we may
consider to be, or to pose a risk of being, illegal, unethical or legally
actionable.
We may share
aggregate or anonymous information about you with advertisers, publishers,
business partners, sponsors, and other third parties.
Facebook
Connect:
If you use one of
our applications and connect to your Facebook account within such application,
you will be providing us with basic account information i.e., user ID, name,
email, gender, birthday, current city, profile picture URL and the user IDs of
your friends who have also connected with our applications. In addition, we
will cache data we receive from the Facebook APIs to improve our user
experience. If you want us to delete the data we receive from Facebook about
you, please contact us at henning@devarai.com.
Offer Wall:
We may display an
"offer wall" in our applications that is hosted by an offer wall
provider. The offer wall allows third party advertisers to provide virtual currency
to users in exchange for interacting with an advertisement or for completing a
marketing offer that may include signing up for an account with one of those
advertisers. These are not offers made by Devarai. These offers may be
displayed to you based on certain technical information, such as your
geographic area or anonymous demographic information. After clicking on one of
these advertisements, you will no longer be on a site hosted by Devarai. To
properly credit user accounts and to prevent fraud, a unique identifier, will
be shared with the offer wall provider.
Invite a
Friend:
You may decide to
provide us with another party’s email address to allow us to contact and invite
that party to visit or join the Service or so that Devarai may facilitate your
communication with such other party through methods of communication enabled by
the Service (such as when you upload an address book). Such email addresses
will be used only for the purpose of sending email communications to the
addressee.
Forums:
Devarai may at
times offer you the ability to post content to a blog, message board, chat room
or within Devarai’s applications or other forums (“Forums"). In order to
do so, you may be required to provide personal information. You should be aware
that any visitor to the Forum may read your postings on the Forum. Furthermore,
any information that you may post to a Forum, including your username or other
Account profile information, will be disclosed and available to all users and
viewers of that Forum, and will therefore no longer be
private. Devarai cannot guarantee the security of such information that is
disclosed or communicated online in public areas such as the Forums, and you
provide such information at your own risk. Devarai does not author, edit,
endorse, or monitor any Forum. You acknowledge and agree that Devarai has no
responsibility for the accuracy or availability of information provided on any
Forum. Devarai reserves the right at any time, in its sole discretion, to
remove any content that a user may post on any Forum and restrict their access
to any Forum.
Security:
Devarai takes
reasonable measures to protect your information from unauthorized access or
against loss, misuse or alteration by third parties.
Although we make
good faith efforts to store the information collected on the Service in a
secure operating environment that is not available to the public, we cannot
guarantee the absolute security of that information during its transmission or
its storage on our systems. Further, while we attempt to ensure the integrity
and security of our network and systems, we cannot guarantee that our security
measures will prevent third-party “hackers" from illegally obtaining
access to this information. We do not warrant or represent that your Account or
any of Your Information will be protected against, loss, misuse, or alteration
by third parties.
Information
Transfers:
Devarai reserves
the right to transfer Your Information in connection with a change or transfer
of Devarai’s ownership or a merger, acquisition, reorganization or sale of
assets or in the event of bankruptcy.
International
Users:
If you are located
outside the United States and choose to provide information to us, Devarai
transfers Your Information to the United States and processes it there. You
hereby consent to any such transfer.
Third Party
Links:
The Service may
contain links to other websites and online services (“Linked Sites”). The fact
that we link to a third party website or service is not an endorsement or representation
of our affiliation with that third party, nor is it an endorsement of their
privacy policies or practices. You acknowledge and agree that we are not
responsible for the privacy practices of such Linked Sites, and this Privacy
Policy does not apply to such Linked Sites. The operators of Linked Sites may
collect information about you, and may use and disclose that information. We
encourage you to review the privacy policies of the Linked Sites that you use.
Opt-In and
Opt-Out Policy:
We will not share
your personal information in ways other than as described in this Privacy
Policy unless you specifically elect to make your personal information
available to third parties by selecting to “opt-in" in various places on
the Service. Your “opt-in" elections will not, however, require us to
share your personal information with any third parties. Further, you may
“opt-out" of any prior elections and of receiving certain types of
communications at any time by contacting Devarai at henning@devarai.com.
Our Policy
Regarding Children:
The Service is not
directed to children under the age of 13. We do not knowingly collect or
solicit personally identifiable information from children under 13. If you are
under 13, please do not attempt to register for an Account on the Service or
send any information about yourself to Devarai. If we become aware that a child
under 13 has provided us with personal information, we will delete such
information from our files.
Contacting Us:
If you have any
questions about this Privacy Policy, please contact us at henning@devarai.com.