PRIVACY POLICY

Effective as of: November 7th , 2018

This privacy policy (“Privacy Policy”) explains how information about you is collected, used and disclosed by SixtyFive02, Inc. and its affiliates (“SixtyFive02, the “Company”, “we”, “our” or “us”). This Privacy Policy applies to information we collect when you use www.sixtyfive02.com and www.littlelike.me, any other websites, mobile applications, web applications, PC desktop applications and other online products and services offered by us (collectively, our “Services”). The Privacy Policy is intended to meet our duties of transparency under the “General Data Protection Regulation” or “GDPR”.

By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Service available at www.sixtyfive02.com/legal/terms-of-service (our “Terms of Service”) and is subject to the provisions of the Terms of Service. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our Terms of Service. If you have any concerns about providing information to us or the use of that information as described in this Privacy Policy you should not use our Services.

Modifications

Because we are always looking for new and innovative ways to help you achieve your goals in connection with the use of our Services, this Privacy Policy may change over time, so please review it frequently. The effective date at the top indicates the last time this Privacy Policy was modified. If we modify the terms of this Privacy Policy, we will notify you by push notification, and/or by posting a notice on our website at least 30 days prior to the effective date of the changes. If we are required by applicable data protection laws to give you enhanced notice or seek your consent for any such changes, we will do so.

Table of Contents

1.     How We Collect Information

2.     Information We Collect That You Choose To Provide To Us

3.     What Information We Collect Automatically When You Use Our Services

4.     Information Provided to Us by Third Parties

5.     How We Use Your Information

6.     What Kinds of Information We Share

7.     Ways You Might Share Your Information through Our Services

8.     How We Keep Your Information Safe

9.     Where We Store Your Information

10.  Our Policies Regarding Children

11.  Your Choices and Controls

12.  How We Respond to Do Not Track Signals

13.  Your Privacy Rights as California Residents

14.  Contact Us

15.  Right to Contact a Data Protection Authority

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1.     How We Collect Information

We collect information: (i) that you choose to provide to us; and (ii) automatically through your use of our Services. If you are a resident of the European Economic Area (the “EEA”), we rely on one of the following legal grounds to process information about you: (i) where we have your consent, (ii) where we have a legitimate interest to do so, (iii) where the processing is necessary for the performance of a contract with you, and (iv) where we need to comply with a legal or regulatory obligation.

2.     Information We Collect That You Choose To Provide To Us

We collect information that you choose to provide to us, for example, when you create an account, manage your user profile, participate in any interactive features of the Services, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The type of information we may collect includes your name, user name, country, date of birth, gender, email address, postal address, mobile phone number, photograph, avatar, password, forum posts and comments, social security number, billing information, payment card number and account details, and other contact or identifying information you choose to provide directly.

3.     What Information We Collect Automatically When You Use Our Services

We automatically collect information about you including:

Device Information. We collect device-specific information when you access our Services from a computer, mobile, and/or other device, including your hardware model, operating system and version, unique device identifiers, mobile network information, country of access, crash reports, request and referral URL’s and system activity details.

Software Information. We collect software-specific information about your use of our Services, such as which version of our software and what updates you have installed or use, and the presence of required plug ins.

Use Information. We collect information about your use of our Services, including the type of browser you use, the language you prefer, access times, pages viewed, user activity, interactions with other users, your internet protocol address and the page you visited before navigating to our Services.

Information Collected by Cookies and Other Tracking Technologies. We use various technologies to collect information, and this may include sending cookies, web beacons, Flash Cookies (as defined below), or other tracking technologies.

-       Cookies. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see Section 11 (Your Choices and Controls) below.

-       Web Beacons. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

-       Other Technologies. There are other local storage and internet technologies, such as local shared objects (also referred to as “Flash Cookies”) and HTML5 local storage that operate similarly to cookies in the way they are stored on your device and can be used to store certain information about your activities and preferences across different services and sessions. Information about disabling or deleting information contained in Flash Cookies can be found here.

4.     Information Provided to Us by Third Parties

In addition to the information that we collect directly from you, we also collect certain of your information from following third party sources.

App Stores or Distribution Channels. Our Services that are distributed through app stores or distribution channels, such as the Apple App Store, Google Play, Steam, and Amazon, may also request permission to automatically collect other information from your mobile or other device. Our Services may only collect such information with your authorization in accordance with your device operating system’s permission process.  

Third Party Services and User Information. We may allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as social media, rewards programs and tournaments. These third parties may use cookies, web beacons, Flash Cookies, your account information (that you provide to such third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your name, account information, profile picture, phone number, email address, gender, date of birth and friends list, your internet protocol addresses, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked and conversion information. Some of such third party analytics and advertising services may offer you a choice to opt-out of the collection and/or sharing of this information. Links to the opt-out mechanisms for the third parties that offer such a choice can be found in the following section. This Privacy Policy does not apply to and we are not responsible for, third party cookies, web beacons, Flash Cookies or other tracking technologies. In addition, we may also receive information about you when other users choose to share their contact lists with us. For example, if you create or log into your account through a social media site, including but not limited to Facebook, Yahoo, Google, Apple, Microsoft and Amazon, we might have access to certain information from that site, such as your name, account information, profile picture, phone number, email address, gender, date of birth and friends lists, in accordance with the authorization procedures determined by such social media site.

We have identified the provider names of some of the third-party analytics and advertising services we use. Please see the links below to learn more about the data practices of our third-party service providers (including opt-out mechanisms they may offer):

-       Facebook: https://www.facebook.com/privacy/explanation

-       Google: http://www.google.com/intl/en/privacy/privacy-policy.html

-       Apple: https://www.apple.com/privacy/

-       Microsoft: https://privacy.microsoft.com/en-us/privacystatement

-       Unity: https://unity3d.com/legal/privacy-policy

 

5.     How We Use Your Information

We may use information about you for various purposes, including to:

-       Provide, maintain and improve our Services;

-       Provide and deliver the products and/or services you order and send you related information, including confirmations and invoices;

-       Send you communications about products, services, offers, promotions, rewards or events offered by us and other companies and provide news and information we think will be of interest to you;

-       Send you technical notices, updates, security alerts and support and administrative messages;

-       Respond to your comments, questions and requests and provide customer service;

-       Monitor and analyze trends, usage and activities in connection with our Services;

-       Personalize and improve our Services and provide advertisements, content and suggest connections or features that match user profiles or activities;

-       Process and deliver contest entries and rewards; and

-       Link or combine with information we receive from others to help understand your needs and provide you with better service.

We retain your data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods: (i) mandated by law, contract or similar obligations applicable to our business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records.

6.     What Kinds of Information We Share

We will share personal information outside of the Company when we have your consent. We’ll ask for your explicit consent to share any sensitive personal information. We do not share your personal information with companies, organizations, or individuals outside of the Company except the following cases:

-       With vendors, consultants and other service providers who need access to such information to carry out work on our behalf, based on our instructions and in compliance with our Privacy Policy and other appropriate confidentiality and security measures;

-       With other users of our Services in connection with the social features of our Services (for example, your username, profile picture and the virtual content, such as virtual currency or virtual items, you have accumulated in our Services that may be visible to other users of our Services, or information that you provide in your account registration for forum use and your forum comments may be visible to other forum users);

-       With location service providers, such as Google Maps;

-       In response to a request for information if we believe disclosure is required by or otherwise in accordance with any applicable law, regulation or legal process;

-       To protect the rights, property and safety of the Company or others;

-       Subject to applicable laws, in connection with any merger, sale of company assets or acquisition of all or a portion of our business; or

-       With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. When we provide this information, we perform appropriate procedures so that the information does not identify you and we contractually prohibit recipients of the data from re-identifying this information to associate the information with you.

7.     Ways You Might Share Your Information through Our Services

Social Sharing Features. Our Services may offer social sharing features and other integrated tools (such as Facebook “Like” button and Twitch “Follow” button, etc.), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide such features.

Location Features. Our Services include features that require collection of specific location data, including: GPS signals, Wi-Fi access points and cell tower identifications if you use the location feature on your device. We only collect this type of data when you activate the location feature on your device. We stop collecting this type of data when you deactivate the location feature on your device. We store this information in your account provided by the Company.

8.     How We Keep Your Information Safe

We take commercially reasonable security measures to help protect information we collect about you from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. These security measures may include practices such as keeping your sensitive data on a secured server behind a firewall, transmitting sensitive information (such as a credit card number) entered while using our Services using secure socket layer technology (“SSL”) and physical security measures to guard against unauthorized access to systems where we store your information. Unfortunately, however, no security system is 100% secure, and we cannot guarantee that the information we collect from you will be free from unauthorized access by third parties. Unauthorized entry or use, hardware or software failure and other factors may compromise the security of user information. Your password is an important component of our security system, and as a result it is your responsibility to protect your password. Do not share your password with any third parties. If your password has been compromised for any reason, you should change your password immediately.

9.     Where and How We Store Your Information

Your information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which the Company, its subsidiaries, or third party agents operate. If you are accessing our Services from outside of the United States, please know the data and personal information you submit may be transferred to and stored on servers in the United States or other countries. The data protection and other laws of the United States and/or other countries might not be as comprehensive as those in your country. If you are a resident of the EEA, we may transfer your information to affiliated entities or third parties to jurisdictions outside the EEA. Please know that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place to allow the transfer of your information across borders outside of the EEA.

10.  Our Policies Regarding Children

As set out in our Terms of Service (available at www.sixtyfive02.com/legal/terms-of-service), you must be at least 18 years old or have the requisite power and authority to access and/or use our Services. If you are between the age of 13 – 17, you must obtain the consent of your parent or legal guardian to use the Services. Our Services are not intended for children under the age of thirteen (13) or the minimum age in the relevant territory if that age is older than thirteen (13) (the “Child” or “Children”), and we do not knowingly collect any personal information from such Children. Children should not use or attempt to use our Services, and if you are Children, please do not attempt to use our Services or send any information about yourself to the Company.

In the event that we learn that we have inadvertently gathered personal information from a Child, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a Child may submit a request to delete such information to privacy@sixtyfive02.com or write to our address listed in Section 14 (Contact Us) below.

11.  Your Choices and Controls

We give you meaningful choices when it comes to important uses and collection of your information. To easily access, view, update, correct, delete or port your personal data, or to update your subscription preferences, please sign into your account and visit “Account Settings”. Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Push Notifications. We may send push notifications or “alerts” to your device to provide information regarding our Services, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.

Promotional Communications. You may opt-out of receiving promotional messages from us by following the instructions in those messages or by contacting us at privacy@sixtyfive02.com. If you opt out, we may still send you administrative, transactional, or relationship messages, such as those about your account or our ongoing business relations including but not limited to administrative confirmations, order confirmations, important updates regarding our Services and notices regarding this Privacy Policy and our Terms of Service.

12.  How We Respond to Do Not Track Signals

Because consumers are often unaware that their do not track beacons are active, do not track frequently does not reflect the actual preferences of our users. We currently do not respond to Do Not Track In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings. 

13.  Your Privacy Rights as California Residents

Under California law, California residents who have an established business relationship with us or one of our subsidiaries may choose to opt-out of our disclosure of personal information about such California resident to third parties for direct marketing purposes. If you choose to opt-out, you may email or write to us at the contact information listed in Section 14 (Contact Us) below.

14.  Contact Us

If you have any questions about this Privacy Policy, please contact us by emailing us at privacy@sixtyfive02.com or by writing to us at:

SixtyFive02, Inc.

101 Broadway

Suite 265,

Oakland, CA 94067, USA

 

15.  Right to Contact a Data Protection Authority

If you have a concern about how we collect and use information, please contact us. You also have the right to contact your local Data Protection Authority. Contact details for Data Protection Authorities in the EEA are available here.