Last Updated: January 21 20201. Introduction
BY ALIENS LIMITED. (“By Aliens,” “we,” “our” or “us”) is dedicated to protecting the privacy rights of our users.
BY ALIENS understands that the protection of individuals regarding the processing of personal data is a fundamental right. Therefore, the principles and rules on the protection of individuals regarding the processing of their personal data should respect, regardless of their nationality or place of residence, their fundamental rights and freedoms, including the right to the protection of personal data.
BY ALIENS is committed not only to protecting the privacy of those who use our sites and applications (collectively, our “Services,” explained in more detail below), but also to contribute to the establishment of an area of freedom and security, environment, economic and social progress, the consolidation and convergence of economies in the internal market and the well-being of natural persons.
As detailed in By Aliens’ Terms of Service, our Services include games, websites, including but not limited to byaliens.com (collectively, “Websites”), the BY ALIENS services provided on or through the websites and/or accessible through various desktop and mobile web browsers, locally installed mobile web applications including but not limited to the games (“Applications”), third-party platforms, and various API services and other services that we may offer from time to time.
By entering, connecting to, accessing, or using the Services, we provide you with the data processing options and all information regarding the lawful basis; if we want to collect your personal data, we will ask you for permission. We : a) ask you in a way that is clearly understood, explaining exactly what it will do, and it is separate from its other terms and conditions; b) tell you all the organizations that will be relying on your consent; c) ask you to take an action to give your permission. This action has to be positive e.g. ticking a box.
We also do not use pre-ticked boxes as well as we give you a genuine free choice about whether to consent and they need to make you aware that you can take away your consent at any time.
If you or, as applicable, your legal guardian, disagree to any term provided herein, you may not install, access, and/or use the Services and you are requested to promptly erase the Applications, and any part thereof, from your mobile device.
2. COLLECTION AND USE OF INFORMATION BY BY ALIENS
2.1. Information About You that We can Collect
We can collect your personal information as follows:
BY ALIENS may allow third parties, including but not limited to ad networks (“Ad Networks”), advertisers (“Advertisers”), analytics companies (“Analytics Providers”), payment processors (“Payment Processors”), and platform providers (“Platform Providers”), collectively “Partners,” to collect your Information for their own use.
The information that third parties may collect will be always under the interests or the fundamental rights and freedoms of the data subject, taking into consideration the reasonable expectations of data subjects based on their relationship with the controller.
The Information that can be collected by third parties may include the following technical information: type of operation system (e.g. Android, iOS, etc.), type of browser (e.g. Explorer, Firefox, Chrome, Safari, etc.), screen resolution (e.g. 800×600, 1024×768, etc.), language (e.g. English), device type (e.g. Galaxy, HTC, iPhone, etc.) and general geo-location. In addition, In order to enhance transparency and compliance with the Regulations regarding this Policy, the information our partners may collect are encompasses: Device identifiers, such as your IP address, iOS for Advertising Identifier (IDFA), Android Advertising ID; information about your use of applications; Information about the offered, viewed, or clicked ads such as the type of ad where the ad was offered, whether you clicked on it, and whether you visited the advertiser's website or downloaded the advertiser's application.
Partners may also collect a “Persistent Identifier” (such as an IP address, unique device identifier or advertising identifier) from you. BY ALIENS may collect, use and provide access to your advertising identifier in accordance with the applicable Platform Provider's policies.
2.2. Information About You that We Use
The Information we collect is compatible with the purposes for which the personal data were initially collected as well as is used by us only to provide a better Service experience, including but not limited to the following:
2.3. Information About You that We Share
We may share your Information with Partners or allow them to collect your Information from our Services for the purposes described herein, a data subject is, nevertheless, entitled to object to the processing of any personal data relating to his or her particular situation.:
(i) Only by your previous consent, we may share your Information with our Partners, which are described above, for their own activities purposes and subject to their separate privacy (for the first time you accesses the game you have an option to choose whether or not accept it and after your choice, you can change it through game settings at any time). If you have any doubt, please contact us at email@example.com . If you no longer wish to receive communications from any of our Partners, please contact the Partner directly.
(ii) BY ALIENS may engage Partners to perform services on our behalf, like processing payments, analyzing data, optimizing game play, delivering e-mails, hosting services and helping us in our marketing efforts, including managing and delivering advertisements. Such Partners may have access to your Information in connection with the performance of these services.
(iii) We may disclose your Information as required by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law, to investigate a fraud, respond to a government request, enforce or apply our rights or protect the rights, property or safety of us or our users or others. This includes exchanging information with other companies and organizations for fraud protection.
If you have any questions about how the Partners use your Information or for how long they keep it, please refer to their privacy policies linked to in Section 14.
3. COLLECTION AND USE OF INFORMATION BY THIRD PARTIES
3.1. Ad Networks
BY ALIENS publishes advertising on the Services so that we can continue to offer many of the Services for free. Such advertisements are provided by Ad Networks, which are carefully selected to preserve compliance with the applicable privacy laws as well as such information are clear to all users in an accessible format that you can decide not to consent, or change your mind later by activating our specific toll for that purpose.
Nevertheless, we have the necessary tools to formalize your choice, if you decide not to consent anymore, or change your decision later if you have already consented
Note that Ad Networks may collect and use your Information, such as:
The Information collected may be used to:
Ad Networks may collect this Information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time. Such practices are subject to those Ad Networks’ policies, which we recommend you review before interacting with them.
Please note that after clicking on an advertisement you may be redirected to a website that is not hosted by By Aliens.
Moreover, we may, at our discretion, advertise other BY ALIENS Services within our Applications. Such advertisements are not directed towards specific users but are rather broadly posted on random BY ALIENS Applications.
In addition, you may see our Services advertised in other games, applications, websites and places. After clicking on one of these advertisements and installing or accessing the Services, you will become a user of our Services. In order to verify the installation of the Application, a Persistent Identifier may be shared with the third party who published our advertisement.
3.2. Mobile Analytics
BY ALIENS allows Analytics Providers to use and collect users’ Information, such as your Persistent Identifier, MAC address, IMEI, locale (specific location where a given language is spoken), general geo-location information, your Internet Protocol (IP) address, device type, operating system, the links and advertisements on our Services that You clicked on, the amount of time You interact with the Services, the events that occur within the Services, performance data and other statistics.
We display this Information to Analytics Providers in order to improve and enhance the Services by expanding their features and functionalities and tailoring them to our users’ needs and preferences. We also use the Persistent Identifier to generate and aggregate non-identifying information about how our Services are used. We do not link the information we store within the analytics software to any identifying Information you submit within the Services.
If you want (or not) your Information to be collected by Analytics Providers, we offer an opt-in and opt-out options in our game’s settings.
Please refer to our list of Analytics Providers for more information on how to opt out in Section 14.
3.3. Social Media Features and Game Center Features
Our Websites include social media features (“Social Features”), such as the Facebook “like button.” These Social Features may collect your IP address and which page you are visiting; they may also set a cookie to enable the Social Feature to function properly. Social Features are hosted by a third party or hosted directly on the Websites.
Our Applications may enable certain game center features (“Game Center Features”) and may include Social Features as well. The Game Center Features and the Social Features are operated or allow for social integration with certain third-party social networks (“Social Networks”), e.g., Facebook Connect or other third-party platforms (“Social Platforms”).
These Social Networks and Social Platforms are created and maintained by third parties (“Social Partners”) who are not affiliated with and/or controlled by By Aliens.
You should ensure that you have read the Social Terms in order to comprehend how they treat your information and to understand the methods for changing the privacy or sharing settings on the Social Networks and Social Platforms.
If you do not agree to the practices described in the Social Terms, you should not allow the Applications to interact with such Social Networks or Social Platforms. However, you may find that you are not able to enjoy all the features that may be made available by the Applications.
You understand that where you allow interaction with any Social Network or Social Platform, we may share data about you with your contacts which are considered as the user that already has on the applicable social network or social platform(“Contacts”), and vice versa, so that you may enjoy Game Features and Social Features. This data may include, without limitation, your scores and/or progress in our Applications, your name, your social media profile picture, descriptions of your service activity and any test that you may upload. Your Contacts will also be able to send you requests through the related Social Network or Social Platform.
3.4. Tracking Technologies
BY ALIENS may allow Partners to place or recognize industry-wide technologies such as APIs, and SDKs and/or other tracking technologies. It is important to mention that you can choose in advance and at your own discretion whether or not you wish to make your personal data available in the game and that your decision is not only respected by BY ALIENS but also is passed on to our partners.
Such Partners’ technologies (“Partners’ Tech”) may be stored on your device by Partners, rather than by By Aliens.
3.4.1. Opting Out of Tracking Technologies
It is easy to prohibit Partners’ Techs. Most browsers and platforms will allow you to erase Partners’ Cookies from your device’s hard drive, block acceptance of cookies, limit the type of cookies you allow or receive a warning before a cookie is stored. However, if you block or erase Partners’ Cookies, your online experience may be limited, because Partners Cookies are necessary to track and enhance your Services activities.
4. IN-APP PURCHASES
Although our Applications are free, they include in-app purchases (“App Purchases”), but we do not collect personal’s payment information through in-app purchases.
All App Purchases are made through our Partners’ stores (“Stores”). Therefore, in order to make an App Purchase, you will need to access your Store account (“Store Account”), which may require entering the Store password (“Store Password”). You hereby agree and acknowledge that you are responsible for maintaining the security of your Store Password.
You should be aware that some Stores may allow for a short window after the downloading of an Application, during which App Purchases may be made without inserting your Store Password. You should also take into account that OS 2.1 or older versions of Android mobile phones do not require the entering of a Store Password to carry out App Purchases.
Regarding your privacy and in order to prevent accidental or unwanted purchases, you can create a specific password/PIN to prevent it from happening at Apple, Google Play, Windows Phone, Amazon and Huawei.
Please note that purchases of Stores’ credits or currencies may also be subject to their own policies.
5. PURCHASE OF MERCHANDISE
Some of our Services may contain links that will redirect you to a third-party website where they may purchase certain merchandise (“Merchandise”) which are offered for sale or otherwise distributed by third-party vendors (“Vendors”).
The Vendors are responsible for the Merchandise and the Merchandise operations. The Vendors may collect Information from users who wish to purchase Merchandise, which is required in order to enable the purchase transaction (e.g., the User's address in order to deliver them the Merchandise, the User's payment information in order to enable the billing and the processing of payment via various payment methods, etc.).
6. LOCAL NOTIFICATIONS
With your consent, we may send local notifications in order to inform you about our products and services, to communicate you of Application updates and to reengage you in use of the Application. Local notifications are local to your device, contextual and sent in-app only and not from a server or in conjunction with other User information. By clicking on the “Allow” button, you accept local notifications, but you may disable these messages at any time by turning off the notifications from the “Options” or “Settings” page within the Application.
7. SECURITY OF YOUR INFORMATION
Although we make good faith efforts to store the Information collected on the Services in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that Information during its transmission or its storage on our systems.
Furthermore, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers" from illegally obtaining access to this Information.
We do not warrant or represent that your Information will be protected against loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. BY ALIENS will not be liable for any harm or damage suffered by you due to any loss, misuse or alteration of your Information by third parties.
8. DATA RETENTION
We may retain your Information for as long as your Account is active or as needed to provide you services. If you wish to cancel your Account or request that we no longer use your Information to provide you services, contact us at firstname.lastname@example.org. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
If you want to know for how long our Partners keep your Information, please refer to their privacy policies, available in Section 14.
9. POLICY CONCERNING CHILDREN
Our Policy concerning children is established separately, in accordance with the laws governing the subject and are available in our website.
We do not directly collect and store any information from children. Some information may nonetheless be collected through and maintained by By Aliens’s third-party providers of certain products or services, such as Ad Networks, Analytics Providers, etc.. You, as a parent or legal guardian of a Kid, can find a full list of such third-party providers in Section 14.
10. CalOPPA – CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our Users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. California residents have the right to receive:
a) information identifying any third-party company(ies) to whom BY ALIENS may have disclosed (within the previous calendar year) Personal Information pertaining to You and your family for that company’s direct marketing purposes; and
b) a description of the categories of Personal Information disclosed.
If You are a California resident and wish to obtain such information, submit a request here at email@example.com with "Request for California Privacy Information" as the subject line and in the body of your message. Please be aware that not all information sharing is covered by requirements and only information on covered sharing will be included in our response. Please also note that under California law, businesses are only required to respond to a customer request once during any calendar year
Users who are resident in the European Union have the following rights:
a) to access and receive a copy of the Personal Information BY ALIENS holds about you, free of charge, with a time limit of one month to respond,
b) to rectify any Personal Information held about you that is inaccurate or incomplete and
c) to request the erasure of personal data, in some circumstances, held about you without undue delay when the use or other processing of such personal data is no longer necessary for the purposes for which is was collected or otherwise processed, and in certain other circumstances,
d) to restrict the processing of your personal data by us, in some circumstances,
e) to request receipt or transmission to another organization, in a machine-readable form, of the Personal Information data that the we hold,
f) to object to the processing of your personal data for marketing purposes and/or on grounds related to your particular situation.
From time to time we may ask you to confirm the accuracy of your Personal Information. You may have the right.
You can exercise your rights by contacting us using the details on section 13.
You will be deemed to have accepted such changes by continuing to use the Services.
13. CONTACT US
BY ALIENS LIMITED
111 Connaught Road Central, RMS 2103-04
Hong Kong. Hong Kong
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