Effective date: November 18, 2020

We respect the privacy rights of our customers 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. Please take a moment to familiarize yourself with our privacy practices that apply to our games Pulley Platformer, and World Warp among others, and let us know if you have any questions.

1. Protecting Your Privacy

This privacy notice applies to any Double Fox Games S.A.S. games , website, application, service or tool (collectively “Services”).

We are committed to protecting the privacy of all people who use our services. Being a Colombian company, we comply with Colombia’s Privacy laws Law 1581 de 2012 and Decree 1377 de 2013 (“Privacy Act”) and follow the privacy principles that are a part of the Privacy Act. Additionally, we seek to comply with acts from the United States of America, which are: COPPA, the United State’s Children’s Online Privacy Protection Act, CCPA, the Californian Consumer Protection Act of 2018 and 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 Notice and GDPR, Double Fox is the data Controller with regard to any data we collect from you, unless otherwise specified.

Double Fox S.A.S. (“Double Fox”) provides interactive software products (“Games”) under its “Double Fox” brand name using various 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 http://doublefoxgames.com/, (our “Sites”) to provide access to information about Double Fox, the Games and Products, message boards, head to head match play or provide technical support to Double Fox customers (collectively, our “Content”).

We are providing this Privacy Policy Notice 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 such data. This 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 are required to comply at all times with the Terms and Conditions (located athttp://doublefoxgames.com/terms-and-conditions.html), and any violation thereof or abuse of our Services, including violations that may impact your privacy rights or the privacy rights of other end users, may lead to the suspension or termination of your access to our Services.

2. What Personal Information Do We Collect?

Personal information is information that identifies you and that may be used to contact you online or offline. We collect personal information from you on a voluntary basis as described below. Our primary goals in collecting and using information is to create your account, provide Services to you, improve our Services, contact you, conduct research and create reports for internal use and for use with our partners.

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 Web site addresses may be logged automatically. We may use this information to monitor and analyze your use of the 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, user names and e-mail and mail 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 company news and promotions. Your gender and birthday may be used to analyze user trends and target certain promotions. Your mail address may be used if we have merchandise or other physical promotional materials that we want 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 applications or other 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 provide 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 contact@doublefoxgames.com. In the alternative, and if the feature is available on the forum in question, you may also have the option to delete your content 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, we will do our best to remove such content from our own application and pages.

iOS and Android Platforms

When you use any of our Games or applications 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 Google+), 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, Game Center and Google+

You may connect your Double Fox user account to your accounts on the following social networking services “SNS”): Facebook, Google+ and Apple’s Game Center. 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 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 friends that are also connected to our Games.

If you want us to delete the data we receive from Facebook, Game Center or Google+ about you, please contact us at contact@doublefoxgames.com

Invite a Friend

Double Fox 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 contact@doublefoxgames.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 gaming experience with our Games and notify you about company news and promotions.

Game Data Collection

Whenever you play our Games, we collect data about your interactions with the Game and with the other players 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 Service, your participation in surveys regarding the Service or your participation in a sweepstakes or contest through the Service.

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, 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 Service (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 Service 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 the Service.

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 visits to our Service 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 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 check 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) 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 Mobile Analytics, Google Analytics, Unity Analytics and Appsflyer. 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.

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 website or Games, you should consult that website’s privacy policy before providing any personal information.

You can opt-out of Google Analytics with this browser add-on tool: https://tools.google.com/dlpage/gaoptout

Ad and Offer Networks

We may feature advertising and offers within our Service. The advertisers may collect and use information about you, such as your Service session activity, 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 website or Games, you should consult that website’s privacy policy before providing any personal information.
Our Advertising partners might change from time to time. We encourage you to review this privacy policy in order to learn who they are. 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 Service. 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 Double Fox.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.

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 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 obligation, protect your vital interest, or as may be required for the public good. This includes:

• 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
• To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities
• To enforce our Terms of Service or other policies, and to comply with this privacy policy notice, 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 Double Fox and our selected partners
• Identify and suggest connections with other Double Fox 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 personalized advertising.
• Internally measure our marketing campaign performance.

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

• Provide personalized 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-personalized ads via our third party providers. Where additional information is collected for the purpose of providing personalized ads, we require your consent before we will collect or share that information. We believe that on balance we do not compromise your rights as a data subject by collecting this data pursuant to our legitimate interest.

4. Who Do We Share Your Information With?

We do not share your personal information except as approved by you 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 the Game, its features and performance.

With your consent, for example, when you agree to our sharing your information with other 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 the 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 guest 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 Double Fox are hosted using various Amazon Web Services (AWS) among other cloud technology providers. 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 Colombia to store information and archives. These third party servers may be located in diverse geographic areas located outside of Colombia and outside your country of purchase and such countries may have different data protection laws and/or privacy laws than the laws identified at the top of this Privacy Policy. 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. 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 contact@doublefoxgames.com.

8. Is Sensitive Information Collected?

We do not ask you to provide any “sensitive information” as a requirement to use our website or any of our Games. “Sensitive Information” means any personal information related to health, 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 Notice. 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 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 you may send an email to contact@doublefoxgames.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:

The name of the Double Fox Game or websites 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 would prefer

We will respond to your request within thirty (30) days. We will ask that you provide certain information to verify your identity. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. We will do our best to delete the information.

Controlling Personalized 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 personalized ads in our games:

For iOS devices

You can reset your advertising identifier in General->Privacy->Advertising->Reset Advertising Identifier

Or limit ad tracking by enabling the Limit Ad Tracking option

For more information see: https://support.apple.com/

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.

Some Ad networks used in our Games and Sites request your consent before collecting any personal data for the purposes of serving personalized ads. These typically include in-ad controls to allow you to adjust your privacy settings.

For Facebook ads, you can control your personalized ad settings in the privacy settings on their web page.

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 site 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 Google + can be found here. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of 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 them 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 contact@doublefoxgames.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 notice, 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 a country that has adopted GDPR (namely, EU Member States), you may contact the regulatory authority in your Member State responsible for administering rights with regard to GDPR. You may also contact our reporting authority in the United Kingdom, the Information Commissioner’s Office, by following this link: https://ico.org.uk/

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 site 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 the Game regarding your personally identifiable 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 is 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 Sites and Games. 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 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 parents for the collection of personal information from their children, or for sending information about our products and services directly to their children

Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity

If you wish to review or change the information we have about your children, email us at info@xdoublefox.com.

12. California Residents: Your California Privacy Rights

Under the laws of the State of California (US), California Residents 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 direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email contact@doublefoxgames.com.

In September 2013, California enacted amendments to the California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) which require 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. While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the web sites 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 out collection and use of personally identifiable information will continue to operate as described in this policy.

Double Fox complies with the California Consumer Privacy Act (CCPA). This was enacted in 2018 and takes effect on January 1, 2020. This landmark piece of legislation secures new privacy rights for California consumers.

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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

• Directly from our end users. For example, from customers who engage us for customer support or to provide customer feedback.
• Indirectly from our end users. For example, through information we collect from our end users in the course of providing customer support to them.
• Directly and indirectly from activity on our website or in our games. For example, from APIs and cookies (described above) embedded in our website or games to measure game metrics and progress, play time per level, and other information related to improving our products.
• 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

You have the right to opt out of the sale 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 data access requests by phone during regular New Zealand business office hours by calling +64 4 978 9400. Note we will ask for some confirmation details before actioning any request.

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. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 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 useable 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.

13. Changes to the Policy

We reserve the right to change this Policy at any time. If we decide to change this 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 Notice and personal information, please contact:

• By email: contact@doublefoxgames.com