PRIVACY POLICY OF SMART EGG PRODUCTION & LICENSING LTD.

Updated on 12 October, 2015

Smart Egg Production & Licensing Ltd. (hereinafter referred to as „SE”), company based in Hong Kong, are committed to respecting the privacy rights of the customers, visitors and other users of SE’s mobile game Smart Egg Labyrinth Run and its related website http://smarteggtoy.com.

We created this Privacy Policy to give you, the user, confidence as you visit and use the website or the game, and to demonstrate our commitment to fair information practices and the protection of privacy. By visiting the website or using the game, you consent to our collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy. This policy is only applicable to the website and the game, and not to any other third-party websites that you may be able to access from the website, each of which may have data collection and use of practices and policies that differ from this Privacy Policy.

By viewing, opening the website, creating an account and/or using any of SE’s online or mobile products, you accept this Privacy Policy. According to the Privacy Policy, your data will be stored in Hungary, European Union.

In case of any changes in our Privacy Policy, we will publish modifications to our Privacy Policy on our website in order to let you know what kind of data we collect, how we use them and under what circumstances we disclose them. We reserve the right to modify the present Privacy Policy at any time, therefore, please read it frequently. If we substantially or significantly modify the present policy or the way we use your child’s data, we will inform you or your parents/guardian of the changes via email or on our website. By continuing using our online or mobile products and services, you accept the modifications to our online Privacy Policy.

SE and its partners know how important it is to you how we collect, use and share information related to you. We greatly appreciate your confidence in our careful and reasonable procedure. We respect the personal rights of our consumers, and acknowledge the importance of the protection of the information collected about you. The aim of the acceptance of this global online Privacy Policy is to provide information about how personal and non-personal data collected on our websites and mobile platforms during the use of our online products and/or services (including online games) is stored and used.

We would like to draw your attention to the fact that our present policy applies only to the websites maintained by SE, and it does not apply to websites maintained by companies or organizations given by us via links.

SE collects personal and non-personal data about its users. Personal data collected by SE are dealt with in the following chapter. Non-personal data are dealt with in Chapter 3.

All information that enables the identification of the user, or enables contacting him/her online or offline is regarded as personal data. SE can collect personal data about its online visitors on the following occasions:
•    Requested client support and/or technical service;
•    Match against a player and other online eye to eye matches;
•    Registration for games and/or certain game-related event;
•    Newsletter subscription, further recommendation and other marketing surveys, e-mail campaigns;
•    Registration for service accounts;
•    Creation of personal profile;
•    Ordering a product, a service and/or a subscription;
•    In all other cases when the use of and/or participation in our software, mobile or online services requires personal data.

The collected data may vary depending on the activity, and can include the followings: name, email address, address, date of birth and mobile phone number.

By using non-personal data, the user cannot be identified and contacted. SE collects non-personal data about the use of its online and mobile products and services on the website, and during the use of its games and software (on PC, mobile and on the game platform) as well.

Your data are stored until the account is active in order to be able to provide the requested services.

3.1    What kind of non-personal data does SE collect?

During the use of SE’s mobile products and services, we may collect certain data not suitable for identification in order to improve the quality of our products and services, troubleshoot, provide services, deliver software updates, provide contents dynamically, support products and communicate. The non-identifiable information collected in this way can be the user’s sex, age, postal code, information about the computer, hardware, software, platform, game system, the type of the data carrier, mobile device including unique device identifiers and other identifiers, error reports, Internet Protocol (IP) address, network MAC (media access control) address and connection type. We collect other, non-personal data, username, identifier, nickname, user and game data, result and performance list, click patterns and other information given by the user in questionnaires, among his/her account data, during the creating of his/her friends’ list or shopping. Related to market and demographic studies, personal or non-public data can also be obtained from third parties, which are added to the personal information received directly from the user.

3.2    How does SE collect non-personal data?

Apart from personal data, SE also collects non-personal data when the user actively submits them through various online and mobile operations, such as online and mobile purchases, registration for games and in marketing surveys. SE and its external partners also apply cookies and other technologies to collect passive, non-personal demographic data with which they make the user experience of their websites more personal, and use them for advertising monitoring and other purposes as detailed below. Based on the collected data, we can obtain facts which are not even among the data.

3.2.1    Cookies

Cookies are tiny files applied in web browsers tracking navigation on websites. Information collected by cookies can be related to personal data. They reveal which products you bought in our webstore, which websites you have visited or with which games you have played. Due to this kind of information, your shopping cart can be tracked, and it can be ensured that you do not see the same advertisements all the time. By using cookies, content tailored to your interests can be provided, and the use of websites and games can be monitored. Together with third parties, we collect information about which games our visitors use, how much time they spend playing, on which advertisements or links they click on. On some of our websites, external advertising companies provide advertisements. These advertisements contain cookies. Cookies received through advertising banners are used by advertising companies employed by our company, and SE has no access to these pieces of information. Most browsers are automatically set to receive cookies when certain websites are visited. You can turn off cookies or set your browser to warn you when sending cookies. In this case, however, some parts of our websites will not work properly. Browser settings enable the user to receive a notification every time a website tries to use a cookie on his/her computer, and they also restrict their reception based on the cookie’s type.

Together with third parties, we sometimes apply flash cookies (or ’local shared objects’) on websites using Flash technology. Similarly to the browser’s cookies, flash cookies are tiny files which remember the settings of the website so that its layout and atmosphere can be customized. Similarly to normal cookies, Flash cookies appear as tiny files on the computer. The easiest way to disable them is to implicitly modify privacy settings on Macromedia website: www.macromedia.com

We would like to remind you of the fact that the advertising providers of our games and websites can use cookies or other technologies as well. The application of these is regulated exclusively by their own policies.  We would also like to draw attention to the fact that the present Privacy Policy applies only to the use of SE cookies, and does not apply to the cookies of advertisers.

3.2.2    Transparent GIFs and tracking pixels

Transparent GIFs (or web bugs, markers or tags) are tiny graphic images on a website, in a web-based document or email message. Transparent GIFs are invisible to the user, since they are very small (1×1 pixel), and their color is the same as the background color of the website, document or email message. We do not use transparent GIF technology to collect the personal data of users. In order to collect statistical data related to the use of our websites, the functions or other elements of our websites, however, we may also apply transparent GIF technology. We correlate these data to the user so as to customize user experience and statistically analyze user experiences gained on our websites.

SE and its external partners may also use tracking pixels, which make our advertising more efficient by filtering existing users out of the addressees of our promotional offers or detect new setups.

3.2.3.    Logging

SE and its external partners can also store log files including IP addresses. IP address is a numerical address assigned to the computer by the Internet provider. Generally, log files are used for monitoring website traffic, troubleshooting technical problems and controlling user rights. In case of user abuse on our websites, we can block certain IP addresses or game system identifiers submitted by our licensed hardware manufacturers. Provided that they are available, IP addresses and game system identifiers can be used for personal identification so that we can check if users observe our Terms of Service.

3.2.4.    Analytical measuring devices and other technologies

While users are playing on mobile devices, SE collects non-personal data with its own analytical measuring devices and other analytical devices. These devices and technologies apply server-side diary files, markers, cookies, tracking pixels and other solutions to collect and analyze certain types of information including cookies, IP addresses (to determine approximate geographical location), mobile and other hardware device identifiers, the type, language of the browser, information transmitted by the browser (if such information exists), referring and outgoing sites, URLs, platform type, number of clicks information about media devices, peripheral devices, software, applications installed, domain names and types, incoming sites, visited sites, their order, time spent on various websites, other Internet and website use, gamestate, the exact date of the website’s visit or the game, information about platform about game usage including telemetric data, statistics, use of functions, purchase history, unique hardware identifiers such as MAC address, unique mobile device identifier (if it exists) and other similar data.

The external data analysis companies which collect information on our websites or through our online or mobile products and/or services can combine the collected information with other information obtained independently from us, from other websites or other online or mobile products or services while using the browsers in their own network, or through their own online and/or mobile products or services.
Most of these companies have their own privacy policies.

4.1.    How does SE use the users’ data?

SE uses user data for fulfilling the users’ needs, orders, and sending data related to the account. Based on the personal data submitted, we can also inform you of the new products, their features, expansions, special offers and updating opportunities. You unsubscribe from these notifications any time.

Otherwise, SE uses personal and non-personal data independently or collectively to improve user experience, develop our services, get to know the behavior and preferences of our users, troubleshoot, advertise in a static and dynamic way, authenticate, observe terms of service, develop and ensure the proper operation of our products. In addition, we combine them with information (e.g.: by means of email address), and use them for providing customer service support, loyalty programmes, communication, mediating offers and improving game experience.

By using Facebook, Game Center or other friend search devices created by third parties online or through mobile products/devices, you acknowledge that they facilitate networking, and you allow the SE accounts of your friends to be connected to your social network profile and/or email address. The present Privacy Policy also appeals to the information content of the friend list created in this way available on EA community platforms. Do not forget that those you put on your SE friend list can find and/or identify you in other SE products and services as well. You friends can see the nicknames you use in the SE product family. Select your friends carefully!

If you want to use ’Send to a friend’ service related to a SE product or site, we need to have your friend’s name and email address. We send an email to your friend on behalf of you, and ask him/her to visit our website or try our product. SE stores the name and email address of your friend only for a short time, merely to send this email and control redundancy so that you friend does not get the same message in multiple copies. We do not store and use these data for any other purposes.

You participation in championships or other online game events also depends on the collection, use, storage, forwarding and publication of participation-generated statistical data (e.g. scores, ranking and results) carried out by us.

4.2.    Does SE share my data with third parties?

Without your approval, SE never discloses your data to any third parties. However, we can share anonymous, non-personal, automatically collected and/or public information with third parties. Sometimes you may also share some of your data on your own. You can find more details about the security of information shared on websites and forums operated by SE in Chapter 9. You can allow SE to share your personal data with companies and organizations the products and services of which you are interested in. In order to stop communication with such a sales partner or sponsor, you have to contact the partner or sponsor directly.

SE does not disclose any personal information about children under 18 registered on our website to any third parties, and does not share or disclose any personal information which is not included in the present Privacy Policy. Nevertheless, SE’s management can hand over client data regardless of age to its successor in title or authorized person if the occurrence of merger, acquisition or bankruptcy proceedings seem to be improbable.

We can also share personal data (including personal correspondence) in the following cases: suspicion of misuse regarding our products and services arises; in order to protect rights or observe legal regulations; upon request of government authorities or other competent authorities; if we reasonably suppose that the disclosure of the data alleviates potential or real damages regarding our property, activities, users or any other parties concerned; if we believe that disclosure of the data protects our rights, reveals fraud and /or SE has to act according to officially delivered summons, court order or other authority order. Please remember that the pieces of information published by you on websites operated by SE or its external partners or through services are regarded as public, and data protection does not apply to them.

Further details can be found in Chapter 9.

SE can use, process or store the submitted personal information in Hungary and the European Union, and can use it for the purposes determined in the present Privacy Policy.

These servers and other devices used for data storage can be possessed and operated by a third parties with whom SE signed a data recording and data storage agreement. Data protection laws in other countries may differ from the ones valid in the country where you live. By sending personal data to SE, you allow SE to transfer, store or process your data based on the present Privacy Policy.

Handling user data safely is a priority for SE. According to best business practices, SE takes all the necessary measures to protect the users’ personal data and ensure the security of the systems. On the other hand, no online method or electronic data storage procedure guarantees 100% security. We cannot undertake responsibility for the consequences of illegal access to our servers.

By signing in to our website and clicking on ’Your account’ or ’View your account’ or other account settings, you can always correct or update your account data. If you cannot sign in or want to deactivate your account(s), please contact us at the following email address: support [@] smarteggtoy.com . We are ready to help you check, update or remove data. However, we may keep you data to use them for settling disputes, observing our user agreement and because of technical and legal requirements, restrictions related to the security, invulnerability and operation of our website.

Certain SE mobile products and services are available for all age groups, and do not deliberately collect the children’s data. If a SE online or mobile product or service collects age-related data and the used claims to be under 13, the given product either denies access or request one of the parents/ guardians approval concerning the use and share of the children’s personal information. SE deliberately does not request more information from a child younger than 13 than needed.

Please take into account that if you allow your children to use SE’s online or mobile products and services including general communication services such as email, instant messaging and online forums/groups, your children will be able to communicate and share personal information with users from all age groups.

It is important to talk with your children about online communication and sharing personal information with strangers. Both you and your children can take a look at online security website, where you can find further information about how to use the Internet more safely.

We guarantee the security of the collected information in accordance with the present Privacy Policy (see: Chapter 6 above). Should we modify the way we handle children’s data, we will notify you in accordance with the present Privacy Policy.

You can decide publish data about yourself on SE’s websites when creating user contents or playing games, or in online blogs, on walls, public user profiles and/or on similar forums on our websites. Public information given on these websites is not encrypted, SE’s employees can have access to it and record it. Data protection and confidential data handling do not apply to this website.

You should be aware of the fact that all data suitable for personal identification given during public activities is visible to other users of these forums. They can collect and use them (e.g. for sending unsolicited messages). We bear no further responsibility for the non-personal data you publish on any of these forums.

Please remember that while you are using the Internet, third parties including ad provider networks, analyzing companies may receive certain data from your browser. SE cannot restrict the accessibility of information forwarded by your browser to networks or any other third parties. You can prevent forwarding of certain data by using the security setting of your browser.

If you upload videos, pictures or photos visible to the public to any of our websites, other users can see, collect, copy or use the without your approval. We are not responsible for any videos, pictures, photos or texts you deliberately upload to SE’s websites.

Our website may contain links to other websites such as Twitter, Facebook and YouTube. A link to a given website does not mean that we intend to be connected to the given party, enable or represent the site. By clicking on links by third parties, including clicking on advertisements, you leave SE’s website, and download the chosen website. As we cannot control third parties’ activities, we cannot bear responsibility for the use of your personal data by third parties, and cannot guarantee that the third parties observe data protection and security procedures followed by SE. Please read the privacy policies of all providers whose services you use. When visiting websites of any third parties through links on SE’s website, read the Privacy Policy of the given website before submitting your personal data.

If you have any questions or problems concerning the present Privacy Policy, please contact us at privacy [@] smarteggtoy.com .