Effective April 01, 2018
TYPES OF INFORMATION WE COLLECT
Information You Provide
We and our Service Providers (defined below) may collect information you provide directly via the Services. For example, we collect information when you create an account on the Services; subscribe to our newsletter; participate in Services feedback, questionnaires, surveys, contests, sweepstakes, or other promotions; receive customer or technical support; play our games, or otherwise communicate or transact with us through the Services.
The information we collect may include personal information. “Personal information” means information that can be used to identify you personally (whether alone or in combination), such as your first and last name, email address, phone number, postal address, and payment card information.
If you do not disclose certain personal information to us, you may not be able to access certain aspects of the Services. For example, to create an account, we will require you to provide certain information, including your email address, user name, and password. If you sign up to the Services through a Third Party Service (defined below) such as Facebook, Twitter or Google Plus, we may also collect personal information during the sign-up process. For information on our relationship with social media platforms, please see “Social Media Features” below.
You may choose to voluntarily submit certain other information to us through the Services, including personal information, but you are solely responsible for your own personal information in instances where we have not requested that you submit such information to us.
Information We Collect Automatically
In addition to any personal information or other information that you choose to submit to us via the Services, we and our Service Providers may use a variety of technologies that automatically store or collect certain information whenever you visit or interact with the Services (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, domain names, access times, and other information about your use of the Services. This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with the Services. To the extent we associate Usage Information with your personal information we collect directly from you on the Services, we will treat the combined information as personal information.
The methods that may be used on the Services to collect Usage Information include:
Log Files: Log files may record and store your Usage Information.
Information Collected by Tracking Technologies: Cookies, web beacons, tracking pixels, embedded scripts, location-identifying technologies, device fingerprinting, in-app tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Services or emails, including information about your browsing and activity behavior.
- Cookies: Cookies are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s device. Like many websites, we employ cookies in certain areas of the Services to allow us to provide information to make your online experience more convenient and to enhance your experience with the Services. For example, when you return to the Services after logging in, cookies provide information so that the Services will remember who you are on subsequent visits, speeding up or enhancing your experience of the Services by, for instance, tailoring content to you. A user may configure his or her web browsers to accept or reject or delete the cookies, or notify the user when a cookie is being set, as further discussed in “Your Rights and Choices” below.
- Web Beacons: We employ third party tracking utility software technology called web beacons or clear gifs, that help us better manage content on our Services by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. In contrast to cookies, which are stored on a user’s device, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. In short, clear gifs enable two websites to share information with one another.
- Tracking Pixel: A tracking “pixel” is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and allows for the collection of information regarding the use of the web page that contains the tracking pixel.
- Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
- In-App Tracking Methods: There are a variety of tracking technologies that may be included in mobile apps and games, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app/game and to track user activity across apps/games.
Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:
- Strictly Necessary. We may use Tracking Technologies that we consider are strictly necessary to allow you to use and access the Services, including cookies required to prevent fraudulent activity, improve security or allow you to make use of shopping-cart functionality.
- Performance-Related. We may use Tracking Technologies that are useful in order to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
Some information about your use of the Services and certain Third Party Services may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Services and certain Third Party Services.
For further information on Tracking Technologies and your choices regarding them, please see “Analytics and Advertising” and “Your Rights and Choices” below.
Information from Other Sources
HOW WE USE YOUR PERSONAL INFORMATION
We may use your information, including personal information:
- To manage our Services;
- to process your registration with the Services, including verifying your information is active and valid, and to allow you to log in to the Services;
- to send messages to you in response to your request to perform an activity in connection with your use of the Services, and to contact you regarding any customer or technical support issues;
- to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or any of the Services’ policies, or when necessary;
- to prevent and address fraud, breach of policies or terms, and threats or harm;
- to monitor and analyse trends, usage, and activities;
- to conduct research, including focus groups and surveys;
- to improve the Services or create new service offerings, to customize your experience on the Services, or to serve you specific content that is relevant to you;
- to send you commercial or marketing messages including, newsletters, promotions, updates, special offers, and email communications about our products or services (for information about
- how to manage these communications and marketing efforts, please see “Your Rights and Choices” below);
- for internal business purposes; and
Use of Information for Recruitment Purposes: Where you have provided us with personal information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this personal information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share the information about you, including personal information, under the following circumstances:
Service Providers. We may share your information with our agents, vendors, consultants, or other service providers (“Service Providers”) that we engage for the purpose of fulfilling product orders, processing information on our and your behalf, operating or hosting the Services, or providing services related to the online components of our games. For example, we may engage Service Providers to process payments for the Services. Additionally, we may engage Service Providers to process consumer surveys, fulfill prizes, or to process, analyze, and/or store data, including, but not limited to, analytical data. While providing services for us, these companies may access your personal information. These Service Providers are prohibited from using your personal information other than to provide this assistance and are required to maintain appropriate confidentiality and security measures.
Partners. We may provide your information, including personal information, to our publishing partners and their affiliates in connection with the online components of our apps and games.
Asset transfers. If we become involved in a merger, acquisition, bankruptcy or other transaction involving the sale of some or all of UL’s assets or a line of business, user information, including personal information collected from you through your use of the Services, could be included in the discussions and transferred assets. Should such an event occur, UL will use reasonable means to notify you through a prominent notice on the Services after the deal is complete.
Internal Business Purposes. We may share your information, including personal information, with our affiliates for internal business purposes.
Direct Marketing Purposes. We may share your information, including personal information, with our affiliates, business partners, and other third parties for their own business purposes, including direct marketing purposes (for further information regarding your rights, see “Your California Privacy Rights” and “Your European Privacy Rights” below).
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.
SWEEPSTAKES, CONTESTS, PROMOTIONS
We may offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting personal information. If you voluntarily choose to enter a Promotion, your personal information may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
The Services may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content (collectively, “User Content”), such as on blogs and message boards. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including personal information, in connection with your User Content. Please note that UL does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Services or what others do with information you share with them on the Services. California residents have additional rights set forth in “Your California Privacy Rights” below.
ADDITIONAL INFORMATION YOU SHOULD KNOW ABOUT THIRD PARTIES
SOCIAL MEDIA FEATURES
ANALYTICS AND ADVERTISING
Third parties may use Tracking Technologies in connection with the Services. For example, analytics services may use Tracking Technologies on our Services to help us analyze your use of the Services, compile statistic reports on the Services’ activity, and provide other services relating to Services activity and Internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Services and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Services (“Interest-based Advertising”). We may not control those Tracking Technologies and we are not responsible for them.
Please click on the links below to learn more about some of these third parties and their privacy policies:
Google Analytics – https://www.google.com/policies/privacy/
For further information on Tracking Technologies and your choices regarding them, please see “Information We Collect Automatically” above and “Your Rights and Choices” below.
YOUR RIGHTS AND CHOICES
Accessing, Reviewing, Correcting and Deleting Your Data
You have the right to access the personal information that you have voluntarily provided to us through the Services, and to review, correct, or delete it. To access, review or correct your information, please send an email to: email@example.com or write to 308 OCCIDENTAL AVE S, STE 200, SEATTLE WA 98104-3884; Attn: Privacy. To delete your account, please send an email to: firstname.lastname@example.org. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). In some cases, we may not be able to delete your personal information, and will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. With respect to our apps, you can stop all collection of information via the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.
Please be aware that if you disable or remove these technologies some parts of the Services may not work and that when you revisit the Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what website and app operators should do with regard to these signals. Accordingly, we do not monitor or take any action with respect to these “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Analytics and Advertising Tracking Technologies
You may choose whether to receive Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt-out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). UL is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
You may opt-out of receiving marketing emails from us and our Service Providers at any time: (i) as provided in any email to click on the unsubscribe link; (ii) by sending an email to: email@example.com; or (iii) by mailing us at: Undead Labs, LLC, 308 OCCIDENTAL AVE S, STE 200, SEATTLE WA 98104-3884; Attn: Privacy. We will try to make the requested changes in our active databases as soon as reasonably practical. Please note that you cannot unsubscribe from non-promotional emails from us, including messages relating to your account transactions, servicing, or UL’s ongoing business relations.
We may send you push notifications until you remove our games or mobile applications or opt-out by adjusting the permissions on your mobile device.
Your California Privacy Rights
Under California law, California residents who have an established business relationship with UL may receive certain information upon request about UL’s disclosure of personal information as defined by California’s “Shine the Light” about them to third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes.
If you are a California resident who has an established business relationship with UL and wish to obtain information about our compliance with this law, please send an email to firstname.lastname@example.org or write to Undead Labs, LLC, 308 OCCIDENTAL AVE S, STE 200, SEATTLE WA 98104-3884; Attn: Privacy. Requests must include “California Privacy Rights Opt-Out Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that UL is not required to respond to requests made by means other than through the provided email address or mail address.
Any California residents under the age of eighteen (18) who have registered to use the Services and have posted content or information on the Services, can request that such information be removed from the Services sending an email to us at [email@example.com]. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.
Your European Privacy Rights
If you are a resident of Europe, including Switzerland, you have the right to ask us not to process your personal information (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You can exercise your right to prevent such processing at any time by contacting us in the following ways: Postal Mail: Undead Labs, LLC, 308 OCCIDENTAL AVE S, STE 200, SEATTLE WA 98104-3884, Attn: Legal Department; By email: firstname.lastname@example.org. We will try to make the requested changes in our active databases as soon as reasonably practical.
PRIVACY SHIELD AND INTERNATIONAL TRANSFER
UL complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Union and Switzerland to the United States, respectively. UL has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.
In accordance with our obligations under Privacy Shield, and subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, we hereby affirm our commitment to subject to the Privacy Shield Principles all personal information transferred from the European Union and Switzerland in reliance on Privacy Shield. This means that, in addition to our other obligations under the Privacy Shield Principles, we shall be liable to you for any third party agent to which we transfer your personal information and that processes such personal information in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages.
In the event that you have any inquiry, dispute, or claim arising out of or relating to our compliance with Privacy Shield, please send an email to email@example.com or write to Undead Labs, LLC, 308 OCCIDENTAL AVE S, STE 200, SEATTLE WA 98104-3884; Attn: Privacy. If we are unable to resolve your complaint directly, you may submit your complaint at no cost to you to JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. In the event there are residual complaints that have not been resolved by JAMS, or any other means, you may seek a non-monetary remedy through binding arbitration to be provided to you in accordance with the Privacy Shield Principles.
To learn more about the Privacy Shield Framework, and to view UL’s certification, please visit https://www.privacyshield.gov/.
We are a general audience service and we do not knowingly collect any personal information from children under the age of 13 as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a child under 13 years of age, you are not permitted to use the Services and should not send any information about yourself to us through the Services. We take children’s privacy seriously and encourage parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when on-line. If you have any concerns about your child’s personal information, please contact us at firstname.lastname@example.org.
WHAT SECURITY MEASURES DO WE TAKE TO SAFEGUARD YOUR PERSONAL INFORMATION?
The personal information that you provide to us is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure the security of such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the Services and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk.
NOTIFICATION OF CHANGES
QUESTIONS? CONTACT US