LUDIA PRIVACY POLICY AND CHILDREN’S PRIVACY NOTICE

Effective Date: May 30th, 2019
Prior Privacy Policy dated January 29th, 2019 is available here.

OVERVIEW

You should read this entire Privacy Policy, but here is a partial list of some of the key topics. Any capitalized terms have the meanings given to them where defined in the Privacy Policy.

INTRODUCTION

Welcome! You have arrived at www.ludia.com and/or are otherwise interacting with our Service (defined below), which is owned and operated by Ludia, Inc. and/or our Affiliates (defined below) (collectively “Ludia” or “we”, or “our”, or “us”). This Privacy Policy governs our collection, retention, use and other processing of personally identifiable and/or personal data (“Personal Information”) obtained in connection with your use of any online service location (e.g., website or mobile app) that posts a link to this Privacy Policy (each a “Site” except when we refer only to our mobile apps, in which case an “App”) (including, without limitation, both mobile and online versions), and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other services that we own and control and make available through a Site and/or that posts a link to this Privacy Policy and to our other interactions with you, such as through our customer support line (collectively, the “Service”), regardless of how you access or use them, whether via personal computers, mobile devices or otherwise.

Some of our Services are directed to children above (i) the age of consent in the EU (which ranges between 13 and 16 years of age depending on the Member State), or (ii) if in the U.S. and Canada over thirteen (13) years of age. However, some of our Services are intended as appropriate for all ages, or in other words a mixed audience of Children and other users (“Mixed Audience”). We refer to “Child” or “Children” as users under the age of consent in the EU Member State in which the child resides, or if in the U.S. or Canada, under thirteen (13) years of age. For these Services, we screen for user age and provide a modified version of the Service for those identified as Children.

This Privacy Policy is limited to our practices and our Service includes access to third-party content and services we do not control. Consult their privacy policies regarding their practices.

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

Where consent to the collection, use and disclosure of Personal Information is required by applicable law, such consent may be given in various ways. Consent can be express or implied (for example, when you provide Personal Information necessary for a service you have requested or the purpose is obvious). You may be asked to provide your specific consent in some special and specific circumstances where notice has been provided to you about our intentions with respect to your Personal Information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any.

By using our Service, you acknowledge you have read and understood this Privacy Policy. To the extent required by applicable law, you consent to this Privacy Policy.

Additional Notice for Jurassic World Alive Users: By using the App, you also acknowledge and accept NBCUniversal’s privacy policy and Google’s privacy policy and terms of service. Google’s and NBCUniversal’s content and/or services are integrated in the App and required for important App functionality (including location-based services) and your acceptance is therefore necessary to use the App.For more information, see Section 4(a).

LINKABLE TABLE OF CONTENTS

This Privacy Policy is posted in interactive format to ease your review, especially using smart phones and other devices with small screens. It is important that you read and understand the entire Privacy Policy before using the Service. Each section below contains a brief introductory summary and a link to the full explanation. Click on the headings and the “More ” buttons to be taken to the full explanation. Any capitalized terms that appear in but are not otherwise defined in the introduction have the meanings given to them elsewhere in the Privacy Policy.

  1. What Information Does the Service Collect?

    We collect and receive certain information about you as you interact with our Service, explained further in this section. More

    1. Information About You That You Provide to Us

      We may collect certain Personal Information and Demographic Information that you provide to us when you interact with the Service. For example, we may collect this information through various forms and in various places on the Service, including job application forms, “contact us” forms, and when you otherwise interact with the Service. More

    2. Information Collected and Stored As You Access and Use the Service

      Certain information may be collected from you automatically when you access and use the Service. For example, we and third parties may use Tracking Technologies to collect Usage Information based on your device identifier (e.g. UID) for a variety of purposes, including (where permitted and in accordance with applicable laws) serving you advertising, based on your having visited our Services or your activities across time and third party locations. We do not look for or respond to Do Not Track signals, but you may have certain other options regarding tracking and/or targeting. This Section provides details on:

      • Usage Information
      • Tracking Technologies
      • Tracking Technologies Usage
      • Tracking Technologies Choices and Consent
      • Third Party Tracking and Do Not Track

      More

    3. Information Third Parties Provide About You

      We may obtain information about you from third parties. More

    4. Third-Party Content and Services

      If you interact with third-party services, such as using Facebook Connect to log in, those services may send us information about you or we may send them information about you. More

    5. Information You Provide About a Third-Party

      You may provide us information about others, such as when you send a friend a message. If so, the information you provide (names, e-mail addresses) may be used to facilitate the communication on your behalf, but will not be used for other marketing purposes unless your friend consents in accordance with any legal requirements. You may be identified to the friend in connection with such a message. More

  2. How Do We Use The Information Collected?

    We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this section including:

    • To provide you with the Services you request
    • To serve Interest-based Advertising, where permitted
    • To respond to your questions or inquiries
    • To process Information for Recruitment Purposes
    • To enable you to post user generated content
    More

  3. Ground For Processing

    Where required by applicable law, we may rely upon a number of legal bases for processing your Personal Information. More

  4. How and When Do We Disclose Information To Third Parties?

    We may provide your information to third parties under various circumstances detailed in this section. These may include:

    1. NBCUniversal and Google

      If you use the Jurassic World Alive App, NBCUniversal (which co-produced the Apps) may receive or themselves collect your personal information in connection with the App. In addition, Google provides an integrated service and may collect device identifier information and precise location data from you via the App. Both NBCUniveral and Google provide services that are necessary for the App to function, including location-based functionality. More

    2. Service partners

      Our service partners may collect Personal Information from you, and such collection and use of your Personal Information shall be in accordance with the privacy policies of the relevant service partner. For example, Unity collects certain of your device-related Personal Information in the course of providing analytics and game optimization Services to us. A copy of Unity’s privacy policy is available here, which contains details on how you can exercise your rights in relation to Personal Information collected by Unity. More

    3. When You Request Information From or Provide Information to Third Parties

      If you request information from third parties, request that we send information to third parties or interact with third-party services, content, ads or tools (including Facebook and other third party services) we may disclose your information to such parties and/or they may collect your information directly. More

    4. Third Parties Providing Services on Our Behalf

      Our service providers may collect your information on our behalf or we may share it with them so that they may provide services to us and you. We may offer you choices regarding the collection and use of your information by our service providers. More

    5. To Protect the Rights of Ludia and Others

      There are a variety of administrative and legal reasons for which we may disclose some or all of your information. More

    6. Affiliates and Business Transfer

      We may transfer your information to our Affiliates (defined below) or disclose it in the event of a sale, merger or similar transaction. More

    7. Sweepstakes, Contests And Promotions

      Promotions that we make accessible or provide you information about may be sponsored or jointly sponsored by third parties. More

    8. Your California Privacy Rights

      We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine the Light law”) collected by us on the Service with unaffiliated third parties for their direct marketing purposes absent your consent (defined below). More

    More

  5. Do Third-Party Content, Links to Third-Party Services and/or Third-Party Apps Appear on the Service?

    We may allow you to access third-party content on the Service, or to link to or interact with third-party applications and locations from the Service, but we are not responsible for third-party content, apps, and locations. More

  6. Are Ads Served On the Service?

    We and third parties may send you targeted ads based on your location, information about your use of the Service and/or behavior, subject to restrictions under COPPA or other applicable privacy or other laws for Children on Mixed Audience Services. If you object, do not use our Service and/or exercise choices some third parties may offer. More

  7. How Do I Change My Information?

    You may change certain account information preferences as fully detailed in this section. More

  8. How Do I Change My Communication Preferences?

    You may change certain communications preferences as fully detailed in this section. More

  9. What About Transfer of Personal Information?

    To the extent required by applicable law, you consent to your data being transferred to the United States, Canada and other jurisdictions where our service providers or partners are located, which have different data protection laws than other countries. More

  10. Your Rights and Choices

    You may have certain rights under applicable law regarding your Personal Information. More

  11. What Should Parents Know About Children? (Children’s Privacy Notice)

    We do not intend to collect Personal Information from Children, except as permitted by applicable law. If you think we have, let us know. California minors have certain content removal rights. More

  12. What About Security?

    No data security is absolute, but we maintain appropriate technical and organizational safeguards to protect your Personal Information. More

  13. What About Changes to the Privacy Policy?

    We may change this Privacy Policy upon posting of a revised Privacy Policy. We will continue to treat your Personal Information under the terms of the privacy policy in effect when it was collected unless we make a material change to our practices, in which case we will provide you with additional notice and/or obtain your consent in accordance with obligations under applicable laws. More

  14. Contact us

    You may contact us to make a query, raise a concern or exercise your rights under applicable law. More

THE FULL DETAILED PRIVACY POLICY

  1. WHAT INFORMATION DOES THE SERVICE COLLECT?

    1. Information About You That You Provide to Us

      Personal Information and Demographic Information. On the Service, we may ask you to provide us with certain categories of information such as: (1) Personal Information, such as your first and last name and e-mail address; and (2) demographic information, such as information about your gender, age, marital status, education level, occupation, hobbies, interests, zip code/postal code, etc., some of which may also be Personal Information (“Demographic Information”). We may collect this information through various forms and in various places on the Service, including at registration, optional surveys, job application forms and “contact us” forms, when you post on the Service, or when you otherwise interact with customer support or with the Service. To the extent Demographic Information is also Personal Information, or to the extent we combine Demographic Information with your Personal Information, we will treat the combined data as Personal Information under this Privacy Policy.

    2. Information Collected and Stored As You Access and Use the Service

      Generally. In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies on your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service. To the extent such information is Personal Information or we associate Usage Information with your Personal Information, we will treat such combined data as Personal Information.

      This Usage Information may include:

      • your IP address, UDID, device identifier or other unique identifier (“UID”). A device identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its device identifier;
      • your Device functionality (including browser, operating system, hardware, mobile network information);
      • the URL that referred you to our Service;
      • the areas within our Service that you visit and your activities there and length of visit, including remembering you and your preferences;
      • your Device location (with your permission or consent);
      • your Device characteristics; and
      • certain other Device data, including the time of day, among other information.

      Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”) in order to improve the Services and better understand and personalize your experiences on the Services. Tracking Technologies may set, change, alter or modify settings or configurations on your Device. The Apps may also receive signals from and otherwise interact with Tracking Technologies that exist in the physical world (e.g., iBeacons, Wi-Fi, and Bluetooth Low Energy at retail locations, discussed below). A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

      • Cookies. A cookie is a data file placed on a Device when it is used to visit the Service. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. To identify local shared objects on your computer and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html

      • Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

      • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

      • Browser Fingerprinting. We may collect and analyze information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification where permitted.

      • ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of UID. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

      • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

      • Location-identifying Technologies. Additionally, and with your consent where required by applicable law, the Services may use GPS (global positioning systems) software and other location-based technologies to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the Services. Upon downloading the App, we provide location-based services to your approximate and/or exact location information. You can opt-out of sharing location data on most Services by adjusting your settings in your device or App.

      • In addition to traditional GPS location-based services., some of the retailers and others we work with may install low power Bluetooth, Wi-Fi, radio transmitters, or other devices in physical locations, which emit a signal that the App can detect to pinpoint your location or otherwise interact with the App (“iBeacons”). Because iBeacons are more precise than GPS, we can improve the Services such as to send you more specific and relevant messages and offers. In addition, you may be able to send your location information via the Services to other Services users. You should consider the pros and cons involved in disclosing your location information to us and to other people. Where a user of the Services requests that their location information be revealed to other persons, the user will be provided options for managing sharing services, which may be through third party services such as through Twitter and Facebook. We are not responsible for the acts, omissions or policies of such third parties.

      • There may be other Tracking Technologies now and later devised and used by us in connection with the Service.

      • Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:

        • Strictly Necessary. We may use Tracking Technologies that we consider are strictly necessary to allow you to use and access our Service, including cookies required to prevent fraudulent activity, improve security or allow you to make use of shopping cart functionality.

        • Performance Related. We may use Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Service.

        • Functionality Related. We may use Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you sign in to our Service or keeping track of your specified preferences, including in terms of the presentation of content on our Service.

        • Targeting and Advertising Related. Depending on your jurisdiction, we may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Service and third party sites based on how you interact with advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements and content delivered to you. Further information on this, and your opt-out choices, is found in Section 8 below. However, the Mixed Audience Services will not use Tracking Technologies, such as cookies, to track user activity for behavioral advertising purposes, except to the extent we do so only for those identified as non-Children. Mixed Audience Services may still use cookies for non-behavioral advertising without regard to a user’s age. Further information on our policies for Children is found in Section 11 below.

      • Tracking Technologies Choices and Consent. We are giving you detailed notice of the Tracking Technologies and your choices regarding them so that your consent is meaningfully informed.

        Regular cookies may generally be disabled or removed through your device settings or tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies go to Adobe’s website https://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies some parts of our Services may not work and that when you revisit our Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations. Further, some Tracking Technologies in connection with non-browser usage (e.g., most functionality of the App) can only be disabled by uninstalling the App. To uninstall an app, follow the instructions from your operating system or handset manufacturer. For information on third party Tracking Technologies and browser Do Not Track signals, see the next section.

      • Third-Party Tracking and Do Not Track. Depending on your jurisdiction, third parties may use Tracking Technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. For more information on our vendors, and their Tracking Technologies, click here. For more information on advertising and advertisers, and related Tracking Technologies, including your choices, click here.

        Various third parties are developing or have developed signals or other mechanisms known as “Do Not Track signals”. There is not yet an industry consensus as to what sites and app operators should do with regard to these signals. Accordingly, we do not monitor or take any action with respect to these signals or other mechanisms, though we may consider doing so if an understandable and practical standard is developed and widely adopted.

    3. Information Third Parties Provide About You. We may receive information about you from your friends and others that use the Service, such as when they submit content to us or post on the Service. Additionally, we may, from time to time, with your consent or as permitted by applicable law, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent this information is Personal Information or we combine information we receive from those sources with your Personal Information, it will be treated as Personal Information and we will apply this Privacy Policy to such information, unless we have disclosed otherwise.

    4. Third-Party Content and Services The Service may include functionality that allows certain kinds of interactions between the Service and a third-party web site, platform, tool, application or other service, and accessing or display of third-party content via the Service. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the Service, you may have an option to use your Facebook or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Service, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our Service, the third-party service may send Personal Information about you to us (such as ad ID and device identifier). In addition, we may provide third-party services’ interfaces or links on the Service to facilitate your sending a communication from the Service. For example, we may use third parties to facilitate emails, tweets, “likes,” content submissions or postings of comments on Facebook or other social media platforms. We may also enable access to or display of third party content via the Service, that is actually being served or published by the third party, and such third party may be collecting data from you in connection with that content. These third parties may collect and retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Ludia may not control or have access to your communications through these third parties. Further, when you use third-party services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party services in connection with our Service.

    5. Information You Provide About a Third-Party

      You may send someone else a communication from the Service, such as sending an invitation to a friend. If so, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication on your behalf and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Service, your contact information, name or user name and message may be included in the communication sent to your addressee(s), except when sent by identified Children on Mixed Audience Services, in which case the Child’s full name and e-mail will not be disclosed to the recipient. If you send a message to a friend, you are responsible for ensuring that you have either obtained the express consent of this friend to do so or that you have a family relationship or a personal relationship with this friend. A “family relationship" means that you are related to this individual through a marriage, common-law partnership or a legal parent-child relationship and have had had direct, voluntary, two-way communication with this individual. A “personal relationship” means that you have had direct, voluntary, two-way communications with this individual and it would be reasonable to conclude that you have a personal relationship with this individual, taking into consideration factors such as the sharing of interests, experiences, opinions and information evidenced in the communications, the frequency of communication, the length of time since you communicated or whether you have met in person. Some of these tools may be third-party tools subject to third-party privacy policies as further detailed in Section 1(d) and Section 5.

      6. Return to Terms summary and navigation

  2. HOW DO WE USE THE INFORMATION COLLECTED?

    Generally. We may use your Personal Information, Demographic Information or Usage Information: (1) to provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Services’ features such as online entry sweepstakes, contests or other promotion; (3) to process your registration with any of the Services, including verifying your information is active and valid; (4) to manage your account and/or upload your User Generated Content (“UGC”); (5) to improve the Services or create new service offerings, to customize your experience on any of the Services, or to serve you specific content that is most relevant to you; (6) to contact you with regard to your use of any of the Services and, in our discretion, changes to the any of the Services and/or any of the Services’ policies; (7) for internal analytics and other business purposes including to prevent and address fraud, breach of policies or terms, and threats or harm; and (8) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy or for any other legal purpose not inconsistent with this Privacy Policy where permitted or required by applicable law.

    Interest-Based Advertising and Location-Based Services. Depending on your jurisdiction and as permitted by applicable law, including COPPA, we may also use your Personal Information, Demographic Information or Usage Information: (1) to specifically target relevant advertisements or content to you both on and off our Services and across your devices or within the Services based on information about your use of our Services, such as your level or achievements (this may include video ads or ads displayed on an offerwall); (2) to understand the usefulness to you of the advertisements or content that have been delivered to you; and (3) when you comment on or add content to the Services. Further, we may use your location information (including proximity to Tracking Technologies existing in the physical world that the App interacts with, for example iBeacons in a retail store) to enable or verify certain actions, as permitted by applicable law, including COPPA. For more on advertising, and your choices regarding it, see Section 6 below. However, we will not serve behavioral advertising (ads based on user profiles built by tracking user activities across sites and on our Services) to identified Children on Mixed Audience Services, though we may serve other ads as permitted by applicable law. Further information on this is found in Section 6 below.

    Contact Us. Please note that information submitted to any of the Services via a “contact us” form or other similar customer inquiry function may not receive a response. If you have a privacy question, please contact us using the contact information below. We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.

    Use of Information for Recruitment Purposes. Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters.

    User Generated Content. The Service may permit you to post or submit UGC including, without limitation, written content, chat messages, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Ludia. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Ludia does not assume any obligation to treat this Personal Information included in UGC in accordance with any usage or sharing limitations or other restrictions and this Personal Information may be used and shared by Ludia and third parties to the fullest extent permitted by applicable law. We encourage you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service’s Terms of Use click here. California minors should see Section 10 regarding potential removal of certain UGC they have posted on the Service.

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  3. GROUNDS FOR PROCESSING

    Where required by applicable law, we may rely upon a number of legal bases for processing your Personal Information, including:

    • The processing is necessary for us to provide you with the services and products you request, or to respond to your inquiries.

    • We have a legal obligation to process your Personal Information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

    • To protect your vital interests, or those of others.

    • We have a legitimate interest in carrying out the processing activity. In particular, we have a legitimate interest if you live in the European Union in the following cases:

      • To analyze and improve the safety and security of the Services. This includes implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.

      • To maintain and improve the Services.

      • To operate the Services and provide you with certain tailored advertising and communications to develop and promote our business.

    • You have consented to the use of your Personal Information. When you consent, you can change your mind at any time.

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  4. HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

    We may share information, such as aggregated user statistics, with third parties. We may share your UIDs with third parties along with data related to you and your activities, subject to the requirements of COPPA and other applicable laws and this Privacy Policy. However, we do not disclose your Personal Information to third parties (other than our Affiliates) for those third parties’ direct marketing purposes or for other purposes except as set forth in this Section 4 (e.g., as part of the sale of our business) without your consent (and in the case of Personal Information of users that have been identified as Children, “verified parental consent” as required by COPPA).

    If we de-identify data about you and such information is no longer Personal Information, and we may share it with others freely. In addition, subject to applicable law (including COPPA where applicable), we may disclose the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. Ludia may disclose your information as follows (subject to applicable COPPA restrictions, more fully explained at Section 10):

    1. NBCUniversal and Google

      If you use the Jurassic World Alive App, NBCUniversal (which co-produced the Apps) may receive or themselves collect your Personal Information or user data through your use of the App. This information includes device information and player data such as purchases, clicks, and sessions for analysis purposes and to improve the App. Google (which provides location services) provides an integrated service and may collect device identifier and precise location data from you via the App. Such collection by NBCUniversal and Google is necessary for the App, including its content features, to function and is governed by their respective terms and polices. To use the App you are required to accept NBCUniversal’s privacy policy and Google’s privacy policy, terms of service, and legal notices. The App will not function without the services provided by these third parties, therefore your acceptance is required to use the App.

    2. Service partners

      Our service partners may collect Personal Information from you, and such collection and use of your Personal Information shall be in accordance with the privacy policies of the relevant service partner. For example, our partner Unity collects certain device-related information in order to provide services to us, such as analytics and game optimization. A copy of Unity’s privacy policy is available here, which contains details on how you can exercise your rights in relation to Personal Information collected by Unity.

    3. When You Request Information From or Provide Information to Third Parties

      You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

    4. Third Parties Providing Services on Our Behalf

      We may use third-party vendors to perform certain services on behalf of us or the Service, such as hosting the Service, designing and/or operating the Service’s features, tracking the Service’s activities and analytics, providing customer support services and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including UIDs and Personal Information, to carry out the services they are performing for you or for us. For Personal Information of identified Children, if we do, we will require that they restrict its use as required by COPPA (e.g., use for our and their internal operations purposes as permitted by COPPA). Our service providers are required to safeguard this data and are not authorized to use this information for their own purposes. Certain service providers may be located outside the United States and Canada and your personal information may be transferred to these other jurisdictions and become subject to the laws of such foreign jurisdictions, including those that may grant access to your Personal Information to the authorities of such foreign jurisdictions. For more information on the manner in which our service providers treat your personal information, contact us as set out below.

      Third parties may also collect and use information about you, potentially including Personal Information, for interest-based advertising purposes as set out in Section 6. In addition, we may use Google Analytics for analytics services, and their privacy policy and consumer choice options are available here: https://policies.google.com/privacy?hl=en. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out or other choice options.

    5. To Protect the Rights of Ludia and Others

      To the fullest extent permitted by applicable law, we and our Canadian, US, or other service providers may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Ludia or third parties (including through the enforcement of this Policy, our Terms of Service , and other applicable agreements and policies); (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas, court orders); or (iii) as otherwise required or permitted by applicable Canadian, US, or other law or legal process, which may include lawful access by US or foreign courts, law enforcement, or other government authorities.

    6. Affiliates and Business Transfer

      We may transfer your information, including your UIDs and Personal Information, Demographic Information and Usage Information to our parent, subsidiaries and affiliates (“Affiliates”) provided that for Canadians, this will be limited to Affiliates acting as service providers to us for the purposes of providing you with the Services, subject to applicable law absent your consent. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change; including, in either case, during the course of any related due diligence process.

    7. Sweepstakes, Contests and Promotions

      We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Service that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list. Promotions on Mixed Audience Services will comply with applicable COPPA requirements.

    8. Your California Privacy Rights

      1. California “Shine The Light” Law

        We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine The Light law”) collected by us on the Service with unaffiliated third parties for their direct marketing purposes absent your consent.

        If you are a California resident, you may request further information about our compliance with the Shine the Light law by contacting us at privacy@ludia.com or by sending a letter to:

        Ludia Inc.
        Attention: California Privacy Rights Request
        410 St-Nicolas Street,
        Suite 400
        Montreal, QC, H2Y 2P5
        Canada

      2. California Consumer Privacy Act (“CCPA”) and Categories of Personal Information Collected, Sold, and Disclosed for a Business Purpose During Preceding 12 Months (California residents)

        This Section supplements the description of our information collection and sharing practices elsewhere in this Privacy Policy to provide, for California residents, a list of those categories of Personal Information as set forth in the CCPA that have been collected and disclosed for business purposes.

        This information collected during the preceding 12 months includes: (1) identifiers, such as IP address and online identifiers, and, if you provide it to us, your name; (2) commercial information, such as a record of your purchases and services you have obtained; (3) Internet and electronic network activity information, such as information about your interactions with the Sites; (4) precise geolocation data; (5) other electronic information; (6) for job applicants, professional and employment-related information; (7) for job applicants, education information; and (8) inferences about you, including about your preferences and characteristics to, for example, tailor the Services for you and provide you more relevant offers and advertising. Some of this information also is considered personal information under Cal. Civ. Code Section 1798.80. In addition, we may collect other Personal Information outside of these categories as described in Section 1 of the Privacy Policy.

        As set forth in the Privacy Policy, Ludia discloses Personal Information to service providers, to protect against fraud and malicious activity, in connection with advertising services, and for other business purposes. During the preceding 12 months, Ludia has disclosed each of the above-listed categories of Personal Information for such business purposes. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through our services and as otherwise permitted under the CCPA.

        In the preceding 12 months, Ludia has not sold personal information, as that term is defined in the CCPA.

        Depending on the circumstances, California residents may have certain rights to access and delete their personal information and to not be discriminated against for exercising these rights. [For more information about how to exercise these rights, please see Section 10 below.]

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  5. DO THIRD-PARTY CONTENT, LINKS TO THIRD-PARTY SERVICES, AND/OR THIRD-PARTY APPS APPEAR ON THE SERVICE?

    The Service may contain content that is supplied by a third-party, and those third parties may collect Usage Information and your UID when such content is served to you. In addition, when you are on the Service you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking your across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Service onto a different site. These third-party services may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, serve you their own ads, have practices that differ from ours and may or may not have their own published privacy policies.

    Third-party applications may also be available via the Service. The owners of these applications (“Third-Party Owners”) may collect Personal Information and other data from you and may have their own policies and practices differing from ours; however, we restrict access for identified Children on Mixed Audience Services. We are not responsible for how Third-Party Owners or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These Third-Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.

    We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

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  6. ARE INTEREST-BASED ADS SERVED ON THE SERVICE OR RETARGETED TO YOU LATER?

    The Service may use third parties such as network advertisers and ad exchanges that use their own tracking technologies on the Services (including cookies and pixel tags) to serve you ads, including interest-based ads, on the Service or to serve you ads, including interest-based ads, on third-party services, websites and apps after you leave our Service, and we may use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Service and viewing of ads and of our content. “Interest-based ads” are behavioral ads targeted to you based on your activities on our Site and App and across third-party sites and apps and across time (such as web pages you visit and your response to ads), including retargeting of ads after you have left our Service and are on a third-party service. Network advertisers are third parties that display advertisements, which may be based on your visits to the Service and other apps and sites you have visited. Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested. You can avoid receiving ads in connection with our Services by not using the Services and by uninstalling our Apps. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace. In addition, some third parties that serve Interest-based ads via mobile apps may offer your choices regarding such practices and their Tracking Technologies. Some may offer a Device-based opt-out option via a downloadable app available at: https://www.aboutads.info/appchoices. We are not responsible for this app, including without limitation its accuracy or limitations, or any representations made in connection with it.

    However, on Mixed Audience Services we will either not serve Interest-based ads at all, or take measures to restrict them to non-Children, though we may serve other ads as permitted by COPPA (e.g., run of service ads, contextual ads, etc.) or other applicable law. Further information on our policies for Children is found in Section 11 below.

    The Service’s third-party ad network and exchange providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a UID. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities. Further information on third-party tracking and Do Not Track is found in Section 1(b) above.

    Third-party Tracking Technologies are not controlled by us, even if they are associated with our Service or our ads. Statements regarding our practices do not apply to the methods for collecting information used by these third parties and others or the use of the information that such third parties collect. The relevant third-party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing or disclosure practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

    Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests. To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

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  7. HOW DO I ACCESS OR CHANGE MY INFORMATION?

    Authorized employees, agents and representatives will have access to your Personal Information, which will be maintained at our offices or on our servers or those of our service providers. We take reasonable steps to protect Personal Information against loss or theft, or unauthorized access, use, modification or disclosure.

    You are responsible for maintaining the accuracy of the information you submit to us. The Service may allow you to review, correct or update Personal Information you have provided through the Service’s forms or otherwise. To the extent required by applicable law, you may request access to your Personal Information in our records and request updates, corrections and changes to your Personal Information by contacting us privacy@ludia.com. If you request changes, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records) and in compliance with applicable law.

    With respect to our mobile and other applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace. Please note that due to technical and other limitations it may not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons (including for our accounting and record keeping obligations) and where we retain your information in such circumstances we will continue to apply the same privacy and security protections described in this Privacy Policy and take reasonable steps to put such information beyond further use. When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for Ludia’s administrative and record-keeping purposes.

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  8. HOW DO I CHANGE MY COMMUNICATION PREFERENCES?

    You may cancel or modify our e-mail marketing communications you receive from us by following the “unsubscribe” instructions contained within our promotional e-mails; this will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited, as indicated to you at the time you opt-out. You can also adjust your push notification preferences within the App or in the settings of your device. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and Service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Ludia, Inc., 410 St-Nicolas Street, Suite 400, Montreal, Quebec H2Y 2P5; By e-mail privacy@ludia.com.

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  9. WHAT ABOUT TRANSFER OF PERSONAL INFORMATION OUTSIDE MY JURISDICTION?

    Our Service is operated in the United States and/or Canada and intended for users located in the United States and Canada. If you are located outside of the United States and Canada, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States, Canada or other jurisdictions where our service providers are located. The data protection laws in the United States and Canada may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States and Canada according to laws of the United States and Canada, respectively, in which countries’ data protection laws materially differ. To the extent required by law, by using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing, disclosure and storage of your information, including Personal Information, in the United States, Canada and/or other jurisdictions as set forth in this Privacy Policy.

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  10. YOUR RIGHTS AND CHOICES

    You may have certain rights under applicable law regarding your Personal Information. Subject to certain conditions, you may ask us to take the following actions in relation to Personal Information in our custody or control:

    • Provide you with information about our processing of your Personal Information and give you access to your Personal Information.

    • Update or correct inaccuracies in your Personal Information.

    • Delete your Personal Information.

    • Transfer a machine-readable copy of your Personal Information to you or a third party of your choice.

    • Restrict the processing of your Personal Information.

    • Object to our processing of your Personal Information for direct marketing purposes.

    • Object to reliance on our legitimate interests as the basis for processing of your Personal Information.

    You can submit these requests by email to privacy@ludia.com or our postal address provided below. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us at privacy@ludia.com or submit a complaint to the data protection regulator in your jurisdiction. You can find information about your data protection regulator here.

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  11. WHAT SHOULD PARENTS KNOW ABOUT CHILDREN (CHILDREN’S PRIVACY NOTICE)?

    Many of our Services are not directed to Children (i.e., under the age of consent in the EU which ranges between 13 and 16 years of age depending on the Member State, of if in the U.S. or Canada under thirteen (13) years of age). Other of our Services are what we refer to as Mixed Audience Services, and are intended for both Children and older users. We do not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) (“Children’s Personal Information”), the GDPR or other applicable privacy law in a manner that is not permitted by applicable law. If you are a parent or guardian and believe we have, please contact us privacy@ludia.com and we will remove such data to the extent required by applicable law.

    For these Mixed Audience Services, we screen for user age and provide a different version of the Service for those identified as under the age of consent in the EU, or if in the U.S. or Canada thirteen (13) years of age, that does not collect Children’s Personal Information except as permitted by applicable law. For example, we disable certain features (such as push notifications and certain tracking technologies) and allow players to log in using a guest profile and generic player name. We may still collect and use IP address and device ID for authentication, fraud prevention, customer support and game optimization purposes. Without limitation, we will either not serve Interest-based ads (ads based on user profiles built by tracking user activities across sites or on the services) on Mixed Audience Services, or do so in a manner that limits Interest-based ads to users identified as non-Children. If you are a parent or guardian and believe your Child has misidentified his or her age on a Mixed Audience Services, or that we have otherwise collected and/or are using Children’s Personal Information in a manner not permitted by applicable law, please contact us privacy@ludia.com and we will discontinue that account, or convert it to a Children’s version, and remove associated Children’s Personal Information to the extent required by applicable law.

    We may also offer subsections of our general audience Services that are identified as for Children (e.g., “KIDS GAMES”), and on such special subsections of our Service we will limit our data collection and use activities to comply with the obligations of COPPA for Child-directed services and other applicable privacy laws.

    For more information on COPPA, click here or visit www.FTC.gov and look for parental guidance on child online safety and privacy.

    Parents may want to consider commercially available parental control protections to limit what minors can access online and/or monitor their minor children’s online activities. Examples include: www.netnanny.com ; www.webwatcher.com and www.sentrypc.com. We do not endorse these or other services and are not responsible for them.

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  12. WHAT ABOUT SECURITY?

    We maintain appropriate technical and organizational safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Although we use reasonable efforts to safeguard Personal Information, we cannot guarantee the security of any information obtained through you use our Service.

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  13. WHAT ABOUT CHANGES TO THE PRIVACY POLICY?

    We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the Privacy Policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

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  14. CONTACT US

    The data controller for your Personal Information is Ludia, Inc., which you may contact by via email at privacy@ludia.com, by phone at +1-514-313-3370 ext 201, or at the following address:

    Ludia Inc.
    RE: GDPR Privacy
    410 St-Nicolas Street,
    Suite 400
    Montreal, QC, H2Y 2P5
    Canada

    You may contact our Data Protection Officer via email at DPO@ludia.com, by phone at +1-514-313-3370 ext 201, or at the following address:

    Ludia Inc.
    ATTN: Data Protection Officer
    410 St-Nicolas Street,
    Suite 400
    Montreal, QC, H2Y 2P5
    Canada

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©2019 Ludia, Inc. All Rights Reserved.