PRIVACY POLICY

EFFECTIVE AS OF FEBRUARY 2016

Please read this Privacy Policy, because it describes the information collection and use practices of TreSensa, Inc. (“we” or “TreSensa”) when you are served a playable ad, game preview or promotion (the “Playable Ad”), which is made available to you through the application, game, website, portal, or platform you are currently using (the “Platform”). This Playable Ad is governed by the terms of this Privacy Policy and any additional terms, conditions, and privacy policies of the Platform (the “Additional Terms”). Please understand that we have no control over or responsibility for any Additional Terms, so we encourage you to read them carefully. This Privacy Policy also covers the information collection and use practices of TreSensa for the websites it owns at www.tresensa.com and www.mobilewebarcade.com (the “Websites”). If you have any questions, please contact us as set forth below.

Children’s Online Privacy Protection Act

We desire and strive to comply with the requirements of the Children’s Online Privacy Protection Act (“COPPA”), which was established by Congress to protect children’s online privacy.  COPPA requires that operators of online services (such as ours) adhere to specific guidelines regarding the collection and handling of personal information about children under the age of 13. For more information about COPPA and your child’s rights to online privacy, please visit the Children’s Privacy section of the FTC’s website at www.ftc.gov.

The Playable Ad is for general audiences and is not directed to children under the age of 13. We do not knowingly collect personal information from children under the age of 13.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information through the Playable Ad without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us without such parental consent, please contact us, and we will endeavor to delete that information from our databases.

Information Collected

We automatically collect the following types of information (collectively, the “Non-Identifying Information”).

1.  From Your Activity

  • IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
  • Browser type and language;
  • Referring and exit pages and URLs;
  • Date and time; and
  • Playable Ad interaction information, such as the amount of time spent on particular portions of the Playable Ad, scores, and other performance and usage data.

2.  About Your Device

  • Type of device;
  • Advertising Identifier (“IDFA” or “AdID”);
  • Operating system and version (e.g., iOS, Android or Windows);
  • Carrier;
  • Geo-location; and
  • Network type (WiFi, 3G, 4G, LTE).

3.  From Cookies

We may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them and other technologies to help us collect Non-Identifying Information and to enhance your experience with the Playable Ad or Websites. Cookies are small text files a website can use to recognize a repeat visitor to the website. We may use cookies for various purposes, including to:

  • authenticate users;
  • personalize your experience;
  • analyze which portions of the Websites or Playable Ad are visited and played most frequently; and
  • measure and optimize advertising and promotional effectiveness.

If you do not want TreSensa to deploy cookies in your browser, you can opt out by setting your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. If you choose to disable cookies in your browser, you can still play the Playable Ad and visit the Websites, although your ability to use some of the features may be affected.

4.  Third-Party Analytics

We, the Platform, and the third-party technologies, ad exchanges and networks with which we work use third-party analytics services (such as Google Analytics, and Mixpanel) to evaluate your use of the Playable Ad, compile reports on activity, collect demographic data, analyze game performance metrics, and collect and evaluate other information relating to the Playable Ad and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Playable Ad.

For Google Analytics, please visit https://www.google.com/analytics

For Mixpanel, please visit https://mixpanel.com

How to Opt Out of Interest-based Advertising and Re-marketing by TreSensa

To date, TreSensa does not engage in cross-app interest-based advertising or re-marketing. If and when we do, we will update this policy accordingly. For ease of reference, if you elect to opt out of interest-based advertising or re-marketing in general, below are instructions you can follow.

Android Users:

For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up:

Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising.”

iOS 7 or Higher:

Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting.

iOS 6:

Go to your Settings >Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting.

The Information Collected by or Through Third-Party Advertising Companies

The Playable Ad may be distributed as an ad unit or as content on the Platform, and we may share Non-Identifying Information about your activity with the Playable Ad with third parties for ad distribution and Ad Optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of the Playable Ad). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect Non-Identifying Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive Non-Identifying Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

In connection with the Playable Ad, neither we nor any third party acting on our behalf employs behavioral advertising or retargeting in connection with users whom we know to be under 13 years old.

How the Information is Used and Shared 

We use the Non-Identifying Information to provide and improve the Websites and Playable Ads, and administer our promotional programs. Also, we may use and share the Non-Identifying Information as described below.

  • We use and share the Non-Identifying Information for Ad Optimization of the Playable Ad.
  • We share the Non-Identifying Information with the Platform on which you are playing the Playable Ad.
  • We may, from time to time, share the Non-Identifying Information with other companies that may provide you information about the products and services they or other third parties offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.
  • In an ongoing effort to better understand our users, we may analyze the Non-Identifying Information in aggregate form in order to operate, maintain, manage, and improve the Playable Ad, the Websites and the Platform. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products, the Playable Ad, and the Platform to current and prospective business partners and to other third parties for other lawful purposes.
  • We may employ other companies and individuals to perform functions on our behalf. Examples may include providing network services, information technology support, and customer service. These other companies will have access to the Non-Identifying Information only as necessary to perform their functions and to the extent permitted by law.
  • We may share some or all of the Non-Identifying Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
  • As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, bankruptcy, or similar event, the Non-Identifying Information may be part of the transferred assets.
  • To the extent permitted by law, we may also disclose the Non-Identifying Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such Non-Identifying Information is necessary or advisable, for example, to protect the rights, property, or safety of TresSensa, the Platform, users, or others.

The Websites

We do not collect any personal information from visitors when they use the Websites unless they provide such information voluntarily, such as by registering or sending us an e-mail or signing up for a newsletter.  All such information (“Personal Information”) is used solely to provide the service for which the information was voluntarily given.

How We Protect Your Information

We take commercially reasonable steps to protect the Non-Identifying Information and Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Non-Identifying Information and/or Personal Information, nor can we guarantee that the Non-Identifying Information and/or Personal Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

California Residents

Because we do not collect Personal Information about your online activities over time and across third-party websites, we do not monitor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Important Notice to Non-U.S. Residents

The Playable Ads and Websites and its servers are all operated in the United States and elsewhere. If you are located outside of the United States, please be aware that any information you provide to us and/or that we collect from you will be transferred to, processed, and used in the United States and elsewhere in accordance with the terms set forth in this Privacy Policy. You hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and other countries.

External Websites

The Playable Ads may contain links to third-party websites, including the Platform. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Playable Ad as soon as they go into effect. By accessing and playing the Playable Ad after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at privacy@tresensa.com.