Codename Crime

Privacy Policy

Last Updated: 20 May 2024

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to Codename Crime (“Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Service?

· We will generate an open ID, which is an internal ID for your account, and will process certain device and network information (such as your IP address) to allow you to use the Service.

· If you register an account for or log in to use the Service (via LEVEL INFINITE PASS), we will need some information from you to set this up. This includes your email address your Open ID. Depending on your use of the Service and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account.

· If you choose to set up your profile using a social media account, we collect information provided by your social media account service provider to automatically generate your profile and they may include user ID, name, user token, open ID, and profile picture.

· To maintain the smooth operation of the Service, we will process customary device and network information such as IP address, network traffic and connection information, device specifications, as well as app- and OS-generated identifiers).

· If you choose to answer a survey, we collect survey response content that you choose to provide in the survey, such as gender, age range, country or region of residency, gaming habits and preferences.

· If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.  

More Information.

How will we use your information?

· We use your information to set up your account, enable you to use the Service, localise the Service experience, enable interaction between users of the Service, save your progress, ensure the safe and secure operation of the Service, address bugs, optimise and improve the Service, protect users, monitor the success of our marketing campaigns, resolve user queries, and to comply with our legal obligations and enforce our legal rights.

More Information.

Who do we share your information with?

· We use third parties and work with our affiliates to help us deliver the best possible experience (such as to deliver system notifications and enabling us to carry out our marketing analysis).

· All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above).

· In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.

More Information.

Where do we process your information? 

 

· We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

· We have servers for the Service in Singapore and the United States. The servers applicable to your use of the Service will depend upon your location. We also have support, engineering and other teams who may support the Service globally.

More Information.

How long do we keep your information?

· Unless otherwise required or permissible by applicable laws, we retain your information for the period of the closed beta test, during which you maintain an account for the Service, or for 30 days upon receipt of a data deletion request. We then delete or anonymise such data, in accordance with applicable laws. 

 

More Information.

How can I exercise my rights over my information?

· Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data. 

More Information.

How will we notify you of changes?

· Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.

More Information.


Welcome to Codename Crime!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Service, and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Codename Crime. If you use any other products or services please refer to the privacy policy for that particular product or service. 

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging how we process your personal information as described in this Privacy Policy.

 

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited (“we”, “us”, “our”). 

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found at contact us here. You can also reach out to our data protection officer at DPO-gst@levelinfinite.com. 

1. Children

Children must not use the Service for any purpose. By children, we mean users under the minimum age for processing personal information as referred to in the regions in the table below. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age. 

Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

Region in which the user is located

Minimum age of the user

Canada

13

Philippines

18

United States

13

 

2. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

Personal Information

Use

Legal Basis (where applicable)

Information you provide to us (either directly or through a third party) 

Service account registration and log-in information:

· Social Media Account Login Information

o LEVEL INFINITE PASS login: openID, token, email address (see https://account.levelinfinite.com/privacypolicy.html)

o Facebook: Facebook UID, name, profile picture, user token, openID

o Google: UserID, nickname, profile picture, user token, openID

· Guest login: Guest ID, openID

· Apple login: userID, nickname, profile picture, user token, openID

We use this information to create your account and log in for the Service in accordance with your request.

Necessary to perform our contract with you to provide the Service.

Email delivery information: email address

We use this information to send you notifications to facilitate creation (such as verification emails) and deletion (such as confirmation emails) of your account for the Service.

Necessary to perform our contract with you to provide the Service in accordance with your request.

IP address

We process this momentarily but do not store it.

We use this information to detect your country/region and to ensure the appropriate version of the Service is provided.

N/A

Information generated as part of the Service

XWIDYour XWID, which is generated by us

 

 

We use this information for guest login and debugging.

It is in our legitimate interest to use this identifier for guest login and debugging.

Common data reporting information: game ID, client source, session ID, event time, client IP, country, province, city, carrier ID, Open ID, event name, OS, OS version, SDK version, network type, bundle ID, app version, login channel ID, device model, device brand, screen width, screen height, CPU name, CPU core,  CPU frequency, GPU name, total ROM, system language, UAID

We use this information for bugs fixing and monitoring the operation of the Service.

It is in our legitimate interest to use this information for bugs fixing and monitoring the operation of the Service.

Data monitoring information: Error code, error message,  SDK name, SDK version, request URL, response body, sequence ID, stage, log, common information for data reporting

We use this information to fix bugs, and to understand the performance and interaction of our SDKs.

It Is in our legitimate interest to use this information to fix bugs and monitor the performance of our SDKs.  

In-Service notifications/ announcements information: openID, device_id

We use this to send you in-game notifications and announcements relating to the Service

Necessary to perform our contract with you to provide the Service.  

Compliance information: open ID, token, region, username and age status. Depending on your jurisdiction, we also process your date of birth momentarily (we do not store this on our servers).

We use this information to verify your eligibility to use the Service.

It is in our legitimate interest to verify users’ eligibility to use the Service.

Data analytics/profiling information (collected via and shared with Appsflyer):

·        Technical information: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier

·        Technical Identifiers: IP address, user agent, IDFA, Google advertising ID, open ID

·        Engagement Information: clicks on our ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, the webpages with the ad where  an end user clicked onto, the URL from the referring website, downloads and installations of applications, and other interactions, events and actions we choose to measure and analyse within our application (e.g. clicks, engagement time etc.)

 

We use this information to carry out data analytics, app performance analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.

It is in our legitimate interest to monitor the success of our marketing campaigns.

 

Crash information (BUGLY):

·     For Android: device name, device model, phone memory, CPU usage rate, CPU model, device system version, device brand, ROM, RAM, CPU architecture, Root status, remaining external SD card space, remaining memory, whether simulator is used, running process information, system time, XWID, process name, network type, application version, application package name, SDK version, SDK version number / application name and version number

 

·     For iOS: device name, device model, phone memory, CPU usage rate, CPU model, device system version, ROM, RAM, CPU architecture, Root status, remaining memory, whether simulator is used, running process information, system time, IDFV (for crash analysis only), process name, network type, application version, application package name, SDK version, SDK version number / application name and version number

 

We use this information to locate and resolve crashes and optimize compatibility.

 

It is in our legitimate Interest to fix crash issues and improve our Service to you.

 

Account deletion information: email address, region, open ID, user token

We use this information to allow you to delete your account upon your request.

Necessary to perform our contract with you to delete your account upon your request.

System notification information via Firebase: device token (for iOS users only) and FCM (Firebase Cloud Message) token (for Android users only)

We use this information to provide you with notifications on your device about the Service.

Necessary to perform our contract with you to send you notifications about the Service.

 

Security-related information:

·     For Android: System version, brand, CPU architecture, system boot time, country code and language, Root status, whether simulator is used, running process information, module information of process, file name list, application package name, process name, application version, startup time, target feature file of SD card, host file, status of cheating behaviour detected, plug-in real-time detection, suspicious APK files within the scope of system authority, critical system library files, open ID

 

·     For iOS: system version, brand, CPU architecture, language region, IDFV, jailbreak status, external file detection status, application package name, application version, startup time, process name, status of cheating behaviour detected, uploading of dylib files information, plug-in real-time detection, VPN connection status, Open ID

 

We use this information for anti-cheating purposes, including to detect and observe cheating behaviours and monitor the presence and operation of suspected cheating activity

It is in our legitimate interest to ensure the security of our Service, to provide a fair environment for players and to improve the Service.

Profanity filter information: 

· log data of SDK (packet records of SDK, IP information of game users) – this is processed on your device unless content violating the Service Agreement is detected, in which case such information is sent to our server)

· error log (open ID and username of player who violated the Service Agreement) 

· text chat data

· voice message information

We use this information to detect and filter content that violates our Service Agreement (the one you agree with upon using our Service).

It is in our legitimate interests to ensure the integrity of the Service and protect users from prohibited conduct.

Survey (device data):

 

· browser information

· user agent information (IP address, browser version, device settings and operating system version)

· user ID, open ID

 

We use this information to provide and enable you to complete the survey.

We collect this information with your consent.

Survey information (via IMUR) (aggregated data): country, game experience feedback, game habit, gender, age range, game preference, email address of Service users (optional), discord ID of Service users (optional)

 

To the extent you choose to participate in an in-game survey regarding the Service, we will redirect you to IMUR Survey to take the survey and the IMUR Survey privacy policy will apply to certain data processed in connection with your participation in the survey.

 

We only receive aggregated survey data from IMUR.

 

We use this information to better understand our users and to improve the Service with your consent.

We collect this information with your consent.

Game data (TLOG): Player ID, Open ID, device information (phone memory, device brand, device system version, device manufacturer, ROM, screen resolution, RAM, system time, device model, device ID, device name, CPU model, CPU architecture, XWID), player game behavior data (player level, in-game performance,  game play experience data), data for optimizing the game, location of the player’s choice

 

 

We use this information to provide, optimize, and to improve the Service to you, and to store your game data.

 

Necessary to perform our contract with you to provide the Service.

Game information:

· Open ID

· IP address, device ID (XWID)

· Role ID, game account, user nickname, country code, device system version, device brand, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, client exports IP, phone memory, login channel ID, operator name, network type, signal strength

· Gameplay statistics (including player level and in-game performance), data for optimizing the Service

 

We use this information:

· to maintain records of log-in and user account actions;

· to improve the Service;

· for security and verification purposes;

· for feedback and information about gameplay and progress.

 

Necessary to perform our contract with you to provide the Service.

Service information: Open ID, device name, device model, login channel ID

 

We use this information:

· to detect and provide for Service updates;

· to provide the game configuration capabilities;

· to ensure smooth and efficient operation of the Service

Necessary to perform our contract with you to provide the Service.

Voice message information:

OpenID, device information (device name, device model, IP address, UUID, system time), SDK version, network type, open ID, voice files (voice data, voice-to-text conversion data), voice message content

We use this information to facilitate your communications with other users and to review if there is any content that violates our Service Agreement if we receive reports of violating content made by users.

Necessary to perform our contract with you to provide voice message function and to provide you with the Service in accordance with the Service Agreement. 

 

Text chat data: Open ID, role ID, username, text chat content

We use this information to:

· facilitate the posting of your communications with other users; and

· to identify chat content that violates our Service Agreement (for example, fraudulent, false, misleading or deceptive, grossly harmful, racially or ethnically objectionable, disparaging, blasphemous, libelous, defamatory, obscene, pornographic, paedophilic, vulgar or offensive, promotes discrimination, bigotry, racism, hatred, harassment or harm, violent, bullying, or threatening or promotes violence, money laundering or gambling, terrorism, or actions that are threatening or disrespectful, promotes illegal or harmful activities) and for us to take actions against such users.

Necessary to perform our contract with you to facilitate the posting of your communications with other users and to provide you with the Service in accordance with the Service Agreement.

 

Performance information:

Open ID, device information (phone memory, GPU information, CPU model, CPU usage rate, device brand, network traffic, device system version, screen resolution, ROM, RAM, device manufacturer, CPU architecture, remaining memory, device model, system time, Firebase performance monitoring (an Android identifier), Whether Root, system startup time, battery status, frames per second, SDK version, network type, application version, application package name

We use this information to monitor performance (for example on your network information), carry out analysis, and to optimize your Service experience.

Necessary to perform our contract with you to provide the Service.

It is in our legitimate interest to monitor your performance for analysis and optimizing your Service experience.

Device information: CPU model, GPU information, Phone memory, Device brand, RAM, ROM, Device model, device name

We use this to analyse the device class (such as the CPU and GPU performance) for optimization of your Service experience with different types of devices.

It is in our legitimate interest to provide you with a better Service experience.

 

3. How We Store and Share Your Personal Information

We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Service in the United States and Singapore. The servers applicable to your use of the Service will depend upon your location. We also have support, engineering and other teams who may support the Service from Singapore.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Services, including providers of services that process information identified in this policy for the purpose of providing the Service, third party SDKs for the purpose of monitoring the success of our marketing and advertising programs and profiling, monitoring and analysing views, clicks and engagement with the advertisements displayed in the Service. Appsflyer and Firebase process the relevant data on their servers located in accordance with their privacy policies. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).

· Third-party partners that we collaborate with in providing the Service, including analytics and marketing companies (e.g. Appsflyer and Firebase), etc. These companies will process your personal information and govern your use of their services and products in accordance with their terms and privacy policies.

· Companies within our corporate group who process your personal information solely for the purpose of providing the Service to you.  All such group companies may only use your personal information in accordance with this Privacy Policy.

· Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying  with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.

· Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4. The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk. 

 

5. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information

Retention Policy

Service account registration and log-in information

Email delivery information

XWID

Data monitoring information

In-Service notifications/ announcements information

Common data reporting information 

Data analytics/profiling information (Appsflyer)

Crash information (BUGLY) 

Account deletion information

Security-related information

 

Survey data (device data)

 

Survey Information

 

Game data (TLOG)

 

Game information

 

Voice message information

 

Text chat data

 

Service information

 

Performance information

 

Device information

 

Stored for 14 days and deleted within 30 days thereafter (unless we receive a deletion request, in which case we will delete within 30 days).

 

 

 

 

 

Compliance information

Except for your date of birth (which we do not store), the rest is stored for 14 days and deleted within 30 days thereafter (unless we receive a deletion request, in which case we will delete within 30 days).

System notification information (via Firebase)

We have no access to this data. Firebase processes this data and it is held in accordance with Firebases privacy policy.

Profanity Filter Information

1. Log data of SDK (upon detection of content violating our Service Agreement), and error log: Stored for 14 days and delete within 30 days thereafter unless we receive a deletion request, in which case we will delete within 30 days 

2. If violating content in the text chat and voice chat data is detected, the violating content is screened out by our filter and we do not store the violating data on our servers.

3. If no violating content is detected at first but it is subsequently reported by other Service users, we store the violating content for 14 days and it is deleted within 30 days thereafter (unless we receive a deletion request, in which case we will delete within 30 days)

IP address

 

We do not store this data.

 

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the Section 2 How We Process Your Personal Information . We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Service account. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the [Service] and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you notifications and announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and notifications and you are not able to opt-out of these notifications, which are not promotional in nature.

7. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: DPO-gst@levelinfinite.com

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

8. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

9. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version (if applicable) of this Privacy Policy, the English version shall prevail.

 

 

 

 

 

 

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the [Service], which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy

By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country or  region where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us. Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Philippines

You are entitled to the following rights:

· Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

· Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.

· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.

· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.

· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

 

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in Section 2 (How We Process Your Personal Information);

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

· transferring or storing your personal information in destinations outside the Philippines as described in Section 3 (How We Store and Share Your Personal Information)

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”),  (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

 

Collection and Disclosure of Personal Information

 

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:

· Identifiers, such as your name as it appears on your social media profile, your LEVEL INFINITE PASS (Open ID, token, email address), your Facebook login (Facebook UID, name, profile picture, user token, openID), your Google login (UserID, nickname, profile picture, user token, openID) and other log-in methods as stated above. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

· Personal information categories listed in the California Customer Records statute, including information covered by other categories such as your address and phone number. This information is collected directly from you.

· Characteristics of protected classifications under California or federal law such as national origin, gender, or age. This information is collected directly from you in the context of being our consumer or, if you choose to set up your profile using a social media account, your gender may be provided by your social media account provider.

· Internet or other electronic network activity information, such as your information regarding your use of the Service, including Wi-fi status, time stamps of actions, zone, log-in and clickstream data and other device information as described in the main Privacy Policy. This information is collected directly from you and your device.

· Geolocation information such as your region location when you set up your profile and choose to provide this information for the Service. This information is collected directly from you.

· Visual information such as your social media profile picture, photos shared in the Service. This information is collected directly from social media platforms and from you, if you choose to sign up using a social media account.

· Account log-in information, including the name used to access your Service account.*

· Contents of your chat messages sent on Service*. This information is collected from your device and is stored on our servers for the duration stated above.

 

We collect and disclose your personal information, for the following purposes:

· To provide you with the Service, maintain your account.

· To analyse and improve our Service.

· To provide you with the Service.

· To provide you with the survey.

 

For additional information about what each type of personal information is used for, see Section 2 (How We Process Your Personal Information).

 

We disclose each of the categories of personal information that we collect as described in Section 3 (How We Store and Share Your Personal Information). 

 

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

 

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

 

Retention of Your Personal Information

 

The retention period varies among the different categories of data collected.  For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.  

 

Rights under US State Laws:

 

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

 

· Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the business or commercial purposes for collecting personal information about you;

o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

o the specific pieces of personal information we collected about you;

· Request to Delete. Request we delete personal information we collected about you;

· Request to Correct. Request we correct inaccurate personal information that we maintain about you;

· Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; and

· Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.   

 

How to Exercise Your Rights

 

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us. We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity.  To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.   

 

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf.  In order for us to process the request, you must provide the authorized agent with signed written permission.  We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

 

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

 

Questions

 

If you have questions or concerns regarding this Privacy Policy, please contact us