TRESENSA

PRIVACY POLICY

EFFECTIVE AS OF October 15th, 2018

Please read this Privacy Policy, because it describes the information collection and use practices of TreSensa, Inc. (“TreSensa,” “we,” “our”) when you are served a playable ad, game preview or promotion (“Playable Ad”), which is made available to you through the application, game, website, portal, or platform you are currently using (the “Platform”). Playable Ads are governed by the terms of this Privacy Policy, and any additional terms, conditions, and privacy policies of the Platform and the advertiser showcased within the Playable Ad (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 its website at www.tresensa.com (the “Website”). If you have any questions, please contact us as set forth below.

EEA Individuals 

Natural persons located in the European Economic Area (“EEA”) should review the General Data Protection Regulation (“GDPR”) privacy notice for their specific rights, remedies, and other GDPR/Privacy Shield-related information here. 

Important Notice to Non-U.S. Residents

The Playable Ads and Website 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, including personal information, will be transferred from your country of origin to the United States. Except in the case of data transfers under the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (as described in the GDPR Notice linked above), your decision to provide such data to us, or allow us to collect such data it through our Website or services, constitutes your consent to this data transfer. 

Children’s Online Privacy Protection Act 

Our Playable Ads are for general audiences and are 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 Ads 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 at Privacy@TreSensa.com with the subject line, “COPPA,” and we will endeavor to delete that information from our databases.


What Information We Collect, The Purpose Of Collection And Use

Contact Information: We collect contact information through the email contact on our Website from visitors and customers who wish to obtain information or support. Such contact information primarily includes first name, last name, e-mail address, and other information necessary for us to properly respond (collectively, the “Contact Information”). This Contact Information is used by our sales, support, and product teams to contact our Website visitors and customers for the purpose of providing the required information or support and/or providing our services.  

Other Information:  In addition to the Contact Information, we may collect or receive the following information: 

Cookies:  Cookies are small text files a website can use to recognize a repeat visitor to the website. We may use cookies to collect the Other Information described above, including by using Google Analytics to drop cookies to analyze which portions of the Website are visited most frequently. 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 visit the Website without any loss of features. For more information on Google Analytics (including opt-out information), please visit http://www.google.com/analytics.

Local Shared Objects: Local shared objects may also be stored on your computer or device (via Mixpanel and internally) when engaging with our Playable Ads in order to collect the data listed in Other Information (e.g., interaction with the Playable Ad, score obtained, click-throughs). Local shared objects operate like cookies, but are not always managed in the same way.  Depending on how local shared objects are enabled on your computer or device, you can manage, clear, or disable them via browser or app settings. For more information on Mixpanel (including opt-out information), please visit https://mixpanel.com/legal/privacy-policy/.

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 Other Information 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 Other Information for such purposes.  Pixel tags enable us and these third-party advertising companies to understand if and when an ad is served and determine the effectiveness of the ad on behalf of the advertiser.

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 to Opt Out of Interest-based Advertising

TreSensa does not serve ads to you based on your personal characteristics besides, at most, high-level interests.  You can use your device settings to opt out of interest-based advertising from us by following the instructions below.

iOS
Go to your Settings > Select Privacy > Select Advertising > Select “Limit Ad Tracking”.

Android
Go to your Settings > Select Services > Select Ads > Select “reset advertising ID”

Data Analysis and Sharing

We may analyze the Other Information in order to operate, maintain, manage, and improve the Playable Ad, the Website, the Platform, and/or the marketing services we provide to our advertisers.  This information does not identify you personally.  We may share this information with the Platform on which you are playing the Playable Ad and also with our advertiser clients, affiliates, agents, and business partners. We may also disclose anonymized and 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.

Additional Uses

We also use Contact Information and Other Information collected pursuant to this Privacy Policy to respond to general inquiries, solicit feedback regarding the Playable Ads and Website, provide relevant content within our Playable Ads and Website, provide and improve the Playable Ads and Website, communicate with you via email regarding our current and future services, and administer our promotional programs.

Onward Transfer to Third Parties

Like many businesses, we hire other companies and individuals to perform certain business-related services. We may disclose personal information to certain types of third party companies, but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: customer service, data storage, hosting services, information technology support, and network services companies.  All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by TreSensa. We may also disclose personal information to our parent companies, subsidiaries, joint ventures, or other companies under common control with us in order to support marketing, sale and delivery of our services.  With regard to the Principle of Accountability for Onward Transfer, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. 

Business Transfers

In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. 

Disclosure to Public Authorities

We may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.  

How We Protect Your Information

We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.  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 information, nor can we guarantee that the 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.

Opt-Out for Direct Marketing; Email Management

You may opt out at any time from the use of your personal information for direct marketing purposes by contacting us at Privacy@TreSensa.com.  Please allow us a reasonable time to process your request.

You may manage your receipt of automated marketing and non-transactional communications by clicking on the “Manage Email Preferences” link located on the bottom of any TreSensa marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional e-mails related to their account or purchase orders. Further, you may always reach out to Privacy@TreSensa.com in cases where you no longer wish to receive emails from the TreSensa team personally (or respond directly within such email).

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or to the extent permitted by applicable law.

California Residents

We do not monitor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.  

External Websites

The Playable Ads may contain links to third-party websites and/or applications, including, but not limited to, links to the Platform, to the website/application of an advertiser showcased within the Playable Ad, or to an app store or other website/application where such advertiser’s products or services may be made available or viewable. 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-parties.  You should check the applicable third-party privacy policy and terms of use when visiting any other websites and/or applications. 

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 and Website as soon as they go into effect.  By accessing and playing the Playable Ad and/or by visiting the Website 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 with the subject line, “Privacy Policy.”