Privacy Policy

CRAYON BOX Privacy Policy | Last Updated: 2015/06/17
1. Your Privacy

This privacy policy (this “Privacy Policy”), as amended from time to time, applies to all of the products and services offered by CRAYON BOX Interactive Inc. or its subsidiaries (collectively, “CRAYON BOX”).

CRAYON BOX respects the privacy rights of its customers and visitors (“Users”) and is committed to protecting the information collected through its online or mobile applications, services and websites (collectively, “Services”). CRAYON BOX has adopted this Privacy Policy to explain how CRAYON BOX collects, stores, and uses the information collected in connection with CRAYON BOX’s Services.

The English version of the Privacy Policy is the governing version. Any translation of the Privacy Policy is just a reference for your convenience and should not be relied on in legal proceedings.

BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING CRAYON BOX’S SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU ARE UNDER 13 YEARS OF AGE, YOU AGREE THAT YOU HAVE THE CONSENT OF YOUR PARENT OR LEGAL GUARDIAN. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES.

2. Information We Collect & How We Use It
CRAYON BOX may collect and use both personal and non-personal data from Users using CRAYON BOX’s Services. This section of the Privacy Policy will describe the type of information that may be collected and how the information may be used.

2.1. Personal Data

2.1.1. Definition

For the purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual and includes those items specifically listed below.

2.1.2. Registering for Services

Users may make personal data such as their name, email address, username and password available to CRAYON BOX when they register for Services, enter contests and special events, subscribe to newsletters, request technical support or otherwise communicate with CRAYON BOX, and when using CRAYON BOX’s Services where personal data is required for use and/or participation.

2.1.3. Information about Users Received from an SNS
When Users access the Services through a social networking site (“SNS”) such as Facebook or Google +, Users allow CRAYON BOX to access certain information from their profile for that site. The information Users allow CRAYON BOX to access varies by application and SNS, and it is affected by the privacy settings you and your friends establish at the SNS. You can control and find out more about these settings at the SNS where you play our games. For example, CRAYON BOX may access and store some or all of the following information, as allowed by Users, the SNS and their preferences:
• first and last name;
• profile picture or its URL;
• user ID number, which is linked to publicly available information such as name and profile photo;
• the user ID numbers and other public data for Users’ friends;
• the login e-mail provided to that SNS when Users register;
• Users’ physical location and that of Users’ access devices;
• gender; and
• birthday.
By using the Services through an SNS, Users are authorizing CRAYON BOX to collect, store, and use, in accordance with this Privacy Policy, any and all information that Users agreed the SNS could provide to CRAYON BOX through the SNS Application Programming Interface (“API”).

2.1.4. Payment Information

If you purchase a license to use in-game virtual currency or virtual items directly from CRAYON BOX, we will collect the billing and financial information necessary to process your charges, which may include your postal or ZIP code and e-mail address. CRAYON BOX may also receive the billing and payment information that you provide when your purchase is processed by another party, such as Facebook (for Facebook Credits) or Apple (for purchases on iOS devices), Google, Barnes and Noble, or Amazon.

Please refer to CRAYON BOX’s Terms of Service to review the policies and terms relevant to our charges and billing practices and the terms of service of third party channels (such as those mentioned above) for their practices and terms of service.

2.1.5. Third Party Privacy Policies

While accessing or using CRAYON BOX’s Services, Users may interact with third parties, such as application stores, mobile software platforms, social networking services and payment providers. Users recognize and agree that CRAYON BOX is not liable for their use of Users’ personal data and Users should review the privacy policies of these third parties.

CRAYON BOX may make available links through advertisements or otherwise enable you to access third party products or services. While using such products or services, you are using products or services that are not affiliated with or controlled by CRAYON BOX. CRAYON BOX is not responsible for those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. Providing links or otherwise enabling access to third party products or services does not constitute sponsorship of, or affiliation with those people or companies.

2.1.6. User Generated Content

Users should be aware of the open nature of certain social networking and other open features of the Services CRAYON BOX may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. CRAYON BOX is not responsible for any personal data you choose to make public in any of these forums.

2.1.7. Minors

Before disclosing a minor User’s personal data to a third party, CRAYON BOX shall disclose:
• the kinds of businesses in which the third parties are engaged;
• the general purposes for which the information is used; and
• whether the third parties have agreed to maintain the confidentiality and security of the information.

A legal guardian may provide consent to CRAYON BOX collecting and using the minor’s personal data, without consenting to the disclosure of the minor’s personal data to third parties.

A legal guardian may review or require CRAYON BOX to delete or stop collecting and further using or disclosing the minor’s personal data at any time by contacting CRAYON BOX at the coordinates found at the end of this Privacy Policy. In this case, CRAYON BOX may no longer be able to provide the same level of Services.

CRAYON BOX does not knowingly collect any personal data from children below the aforementioned age without receiving the consent of a legal guardian. If CRAYON BOX learns that it has inadvertently collected or stored personal data from children under the aforementioned age without the consent of their legal guardian, CRAYON BOX will take reasonable measures to promptly erase such personal data from their records.

2.2. Non Personal Data

2.2.1. Definition

For the purpose of this Privacy Policy, “non-personal data” means: (1) information that does not directly identify you; and (2) “aggregate” and “de-personalized” information, which is data CRAYON BOX collects about the use of CRAYON BOX Services, from which any personally identifiable data has been removed.

CRAYON BOX may use tools or third party analytical software to automatically collect and use certain non-personal data. You will not be identifiable through the use of these tools or third party analytical software. The types of non-personal data CRAYON BOX may collect and use include, but are not limited to:
1. Device properties, including, but not limited to:
(a) IP address;
(b) Media Access Control (“MAC”) address; and
(c) Unique device identifier or other device identifier (“UDID”);
2. Device software platform and firmware;
3. Mobile phone carrier;
4. Geographical data such as zip code, area code and coarse location;
5. Game progress, score and achievements; and
6. Other non-personal data that CRAYON BOX may require to enhance the Services and other CRAYON BOX products.

2.2.2. Trusted Partners and Contractors

CRAYON BOX may use and disclose to its affiliated companies, contractors or other trusted businesses or persons the collected non-personal data for the purpose of auditing, researching and analyzing usage of the Services, ensuring the technical functionality of CRAYON BOX’s Services and to further develop the Services and other CRAYON BOX products.

2.2.3. Cookies, Beacons and Tracking

CRAYON BOX may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. CRAYON BOX treats information collected by cookies and similar technologies as non-personal data.

A “cookie” is a small bit of record-keeping information that is sent to the Users’ computer. CRAYON BOX’s cookies do not include personal data and may be used to: (1) facilitate Users’ login authentication, (2) help Users navigate around the CRAYON BOX’s websites, (3) monitor how many people are using CRAYON BOX’s Services, and (4) store Users preferences and track trends.

Most browsers are initially set up to accept cookies, but Users can disable cookies or set their browser to indicate when a cookie is being sent. However, disabling cookies may affect your ability to use the Services.

CRAYON BOX may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember your settings to personalize the look and feel of the Services. Locally shared objects only collect data in the aggregate.

You may prevent locally shared objects from being placed by disabling locally stored objects in your browser or by visiting www.adobe.com. Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies.

CRAYON BOX may also use web beacons and pixel tags to count Users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications CRAYON BOX sends to you may contain pixel tags that enable CRAYON BOX to track your usage of the communication, including whether the communication was opened and/or what links were followed.

2.2.4. Ad Serving Technology

CRAYON BOX reserves the right to use and disclose the collected non-personal data for purposes of advertisement by CRAYON BOX or CRAYON BOX’s trusted partners and contractors. CRAYON BOX may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through the Services.

CRAYON BOX or third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service. CRAYON BOX or third parties may collect and use data for this purpose including, but not limited to IP address (including for purposes of determining your coarse location), UDID, MAC, software, applications, hardware, browser information, internet and on-line usage information and in-game information.

The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology. You recognize and agree that the advertising companies who deliver ads for CRAYON BOX may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies may be integrated into the Services; if you do not want to be subject to this technology, do not use or access the Services. Although CRAYON BOX may take commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, CRAYON BOX does not have access to or control of third party technologies.

2.2.5. Location Data

If CRAYON BOX makes location enabled Services available and you use such Services, then CRAYON BOX may collect and process your location data to provide location related Services and advertisements. CRAYON BOX may use various technologies to determine location, such as GPS, Wi-Fi or other network-based data such as IP address. Your GPS location is not accessed without your consent. Notwithstanding CRAYON BOX’s partners who are providing location related parts of the Service, CRAYON BOX will not share your geo-location with third parties without your consent. To the extent CRAYON BOX makes available geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously. Please note that CRAYON BOX may share your anonymous coarse location with its partners.

3. Who We Disclose Personal Data To

3.1. Disclosure of Personal Data

In providing the Services, CRAYON BOX may disclose the personal data to other companies or individuals in the following limited circumstances:

1. In cases where CRAYON BOX receives Users’ consent;
2. With applications stores as part of Users’ purchase and use of the Services (including in-app purchases);
3. CRAYON BOX has a good faith belief that access, use, preservation or disclosure of such personal data is reasonably necessary to;
(a) satisfy any applicable law, regulation, legal process or enforceable governmental request;
(b) enforce applicable Terms of Use including investigation of potential violations thereof;
(c) detect, prevent, or otherwise address fraud, security or technical issues; or
(d) protect against imminent harm to our rights and/or property, or
4. As required or authorized by applicable law.

3.2. Data Processing

CRAYON BOX may also disclose Users’ personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of processing personal data on its behalf. CRAYON BOX requires that these parties agree to process such personal data based on CRAYON BOX’s instructions and in compliance with the Privacy Policy and any other appropriate confidentiality and security measures.

CRAYON BOX may disclose Users’ personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of providing marketing and advertising content to Users. CRAYON BOX requires that these parties agree to process such personal data based on CRAYON BOX’s instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. Users can unsubscribe from this service at any time.

3.3. Sale of Business
As CRAYON BOX continues to develop and grow, we may buy or sell parts of a business, which could include personal data as one of the transferred business assets. If CRAYON BOX becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, it will provide notice before personal data is transferred and becomes subject to a different privacy policy.

4. Choices for Personal Data
If CRAYON BOX proposes to use personal data for any purpose other than those described in this Privacy Policy, CRAYON BOX will obtain the Users’ prior consent or offer the Users an effective way to opt out of the use of personal data for those other purposes.
Users may choose to withdraw their consent to the use, collection or disclosure of personal data outlined in this Policy at any time. If a User withdraws his or her consent, then CRAYON BOX may no longer be able to provide the same level of Services.
Users are also given the opportunity to “opt-out” of having their personal data used for purposes such as receiving newsletters or other information from CRAYON BOX.
Withdrawals of consent will not have an effect on data that CRAYON BOX has provided to third parties in accordance with this Privacy Policy prior to such withdrawals.

5. Information Security

CRAYON BOX takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. CRAYON BOX employs physical, electronic and/or procedural safeguards to protect its systems and all personal data under its control against unauthorized access and use. All safety and security measures are appropriate to the sensitivity level of the information collected.

6. Accuracy and Access/Control over Personal Data
CRAYON BOX processes personal data only for the purposes for which it was collected and in accordance with this Policy. CRAYON BOX may take reasonable steps to ensure that the personal data processed is accurate, complete and current, but CRAYON BOX is not responsible for verifying the correctness of personal data.
CRAYON BOX will allow Users to access their personal data in the custody or control of CRAYON BOX, and will allow them to:
1. update or correct such personal data;
2. change User preferences with respect to communications, push notifications and other information received from CRAYON BOX or third parties; or
3. delete the personal data of the Users on CRAYON BOX’s systems (by submitting a request to Customer Support).
Users can turn off push notifications (if applicable) by visiting the “options” or “settings” page within the relevant app. Users can turn off local notifications by visiting the “options” or “settings” page within the relevant app.
Users can stop further use of your geo-location (for example through “check-ins”) (if applicable) by visiting their device’s settings for the relevant application or the “settings” page for the relevant game. Users can also stop checking in.
Such updates, corrections and changes will not have an effect on other information that CRAYON BOX maintains, or information that CRAYON BOX has provided to third parties in accordance with this Privacy Policy prior to such update, correction or change.

7. Retention of Personal Data
CRAYON BOX stores personal data collected pursuant to this Privacy Policy only as long as is reasonably required to fulfil the purposes for which it was collected or as required or authorized by law.

CRAYON BOX may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce CRAYON BOX’s user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Services.

8. Enforcement

It is CRAYON BOX’s policy to contact a complaining user regarding his or her concerns. CRAYON BOX will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between CRAYON BOX and an individual.

9. Changes to this Policy

CRAYON BOX reserves the right to modify this Privacy Policy from time to time, so please review it frequently. If CRAYON BOX makes material or significant changes to this Privacy Policy, CRAYON BOX may post a notice on CRAYON BOX’s website along with the updated Privacy Policy. Your continued use of the Services will signify your acceptance of the changes to this Privacy Policy.

10. Contact Information

Should you have any questions relating to this Privacy Policy, please contact us with support@crayonfriends.com.