Last Updated: March 11, 2020 with effective date March 11, 2020.
The data controller is Loona Inc , with a registered address at 8 The Green, Suite #5370, Dover, DE 19901, USA . Loona Inc as Data Controller does not and will not process any special categories of personal data (“sensitive data”).
Loona Inc as Data Controller
Information and Data we Collect from you
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to identify you (“Personal Data”). Our Services are designed to avoid collecting information such as your name, address, email address or other similar contact data unless you provide such data to us. The information we collect include:
- Automatically collected data (such as IP Address, your device’s operating system, browser type and language)
- Mobile device identifiers (such as your unique device ID (persistent/non-persistent), IDFA (Identifier for advertisers), hardware type
- General location information for the purpose of providing you with the correct version of the application
- Precise-geo-location information from your mobile device (but not in all our applications and games and only with your express consent where applicable)
- Applications and games data (such as your interactions with the application or game and with the other users or players inside the application or game respectively via server log files, your user or player ID)
How We Use Your Information
Loona Inc’s primary goals in using information are to provide Services to you, improve our Service, contact you, conduct marketing and research and create reports for internal use. We store information on servers located in the United States via Amazon Web Services and may store information on servers and equipment in other countries.
We collect information automatically about your activity through our Services, for example date and time you used a service, features you have used, in-app purchase history, subscriptions, and advertising that you click on, and data generated when you use our Services, for example your game progress which may be stored with your Apple ID on iCloud for iOS Devices in some of our Services. Our Services may also contain tools from third party service providers that may enable these third parties to separately collect and/or analyze non-Personal Data from the users' devices.
We may use your information to:
- Operate and improve our Service
- Understand you and your preferences to enhance your experience and enjoyment using our Service
- Respond to your comments and questions and provide customer service
- Provide and deliver products and services you request
- Deliver advertising and marketing and promotional information to you
- Send you related information, including confirmations, invoices, technical notices, updates, push notifications, security alerts, and support and administrative messages
- Communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by Loona Inc and our selected partners
- Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services.
With only your express consent, we or our partners may collect your precise location based information (GPS) for the purpose of tailoring content specific to your area (such as area based content packages), and to match your device location to certain points of interest for purposes of interest based advertising as described elsewhere in this Policy. Please note, participation in this part of the Service is not a requirement for all our applications and games. You may at any time opt-out from sharing your location by turning it off at the device level through your settings.
Information We Obtain from Third Parties
We may receive information about you from our analytics service providers with data they collect through our Services in accordance with their own privacy policies. A list of the third parties that operate in our Services can be found in the Appendix A below.
Information We Obtain from Facebook
We may use your email address when you contact our customer service group to contact you about your application usage and gaming experience with Loona Inc applications and games and notify you about company news and promotions.
If you no longer wish to receive certain email notifications you may opt-out at any time by following the unsubscribe link located at the bottom of each communication or by emailing us with the contact information provided in this policy.
Tracking and Data Collection Technologies
We and our marketing and outsourcing partners, affiliates, or analytics service providers use technologies such as cookies, beacons, scripts, and tags to identify a user’s computer/device and to “remember” things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your personal information, such as your user ID, for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Service easier to use. You can disable cookies at any time.
While you are browsing the 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, develop and analyse your use of the Service.
We may use your email address to contact you about your experience with the Services and notify you about Loona Inc news and promotions.
When you use any of the Loona Inc applications or games on a mobile platform, we may record certain information and data, such as your application usage, access, session times and in-app purchases, your unique device ID (persistent / non-persistent), hardware type, the version of your operating system (“OS”), your device name, and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends and improve and optimize the Services and your user experience, and may also be utilized for interest based advertising as described elsewhere in this Policy.
We may occasionally send you push notifications through our mobile applications about application updates, new content availability and other service related that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.
Rights of Data Subjects
You have the right to request the access and rectification or erasure of personal data or restriction of processing or to object to processing as well as the right to data portability. Further, you have a right to lodge a complaint with a respective supervisory authority.
- The right to rectification is your right to obtain without undue delay the rectification of inaccurate personal data concerning you
- The right to erasure is your right to obtain the erasure of personal data concerning you without undue delay, where certain additional circumstances are fulfilled
- Under certain circumstances you have the right to restrict the processing of personal data;
- You have the right to receive the personal data concerning you, and that you have provided to us, and have the right to transmit those data to another controller, where technically feasible, where the processing is based on consent or on a contract and the processing is carried out by automated means
- You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on respective provisions of the law, including profiling based on those provisions
- Subject to the respective statutory limitations set by the applicable law, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
- Where the processing of personal data is based on your consent you can withdraw such consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
Please use email@example.com to exercise all of the aforementioned rights.
You may also contact your local data protection authority within the European Economic Area for unresolved complaints.
Accessing, Correcting, and Deleting Your Information
Upon request, we will provide you with information about whether we hold any of your personal information. If your personal information changes, or if you no longer desire our Services, you may correct, update, delete inaccuracies, or delete your personal information by making the change within your account settings or by contacting us. We will respond to your access request within a reasonable timeframe.
Opting Out of Marketing
You may opt-out of receiving promotional emails from us by following the instructions in those emails by emailing us with the contact information provided in this policy. If you opt-out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
Data Security and Retention Periods
Keeping Personal Data secure is a topmost priority for Loona Inc . We do our best to protect your information from unauthorized access or against loss, misuse or alteration by third parties, disclosure and other improper processing activities.
We have put in place reasonable and appropriate organisational, technical and physical procedures and safeguards to protect the information we collect and process. These procedures also take into account the type of personal data and the risks related to its possible disclosures. In the following we bring out specific actions with regard to organisational, technical and physical safeguards in place at Loona Inc .
We will also retain Usage Information for internal analytics purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
Your Personal Data collected through our Services will be deleted when they no longer serve one of the above-mentioned purposes but in any event your Personal Data will be deleted after 14 months of inactivity in your use of our Services. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
Our Policy Regarding Children
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for general audiences over the age of 16 years. We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.
Subcontracting and Exporting Personal Data
We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Policy.
Third Party Services
How We May Disclose Your Information to Third Parties
Loona Inc. does not share your personal information except as approved by you or as described below:
- Loona Inc may engage other companies and individuals to perform services on our behalf. An example of these services may include analyzing data and providing customer support. These agents and service providers may have access to your personal information in connection with the performance of services for Loona Inc .
- We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection. In certain situations, Loona Inc may be required to disclose personal information in response to lawful requests by public authorities or for local law enforcement requirements.
- Loona Inc may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notice on our Sites of any change in ownership or users of your personal information.
We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.
Links to Other Sites
For the convenience of our visitors and clients, the Website and application may contain links to other sites, such as those of our partners or vendors, which are subject to different privacy policies. The Policy will not apply to your use of other websites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies found on such other websites, services and applications to understand how your information may be collected and used on these independent sites before disclosing information to third parties.
APPENDIX A: Analytics and Other Service Providers
We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.
Amplitude is an analytics service provided by Amplitude Inc. (US)
Appsflyer is an analytics service provided by Appsflyer Ltd (Israel)
Facebook Ads Conversion
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. (US) that connects data from the Facebook advertising network with actions performed on this Application.
Firebase is an analytics service provided by Google Inc. (US)
OneSignal is a marketing service that provides mobile push notification solutions by OneSignal, Inc (US).