PRIVACY POLICY
Thank you for using our products and services! CRAFTSMAN TECH PTE. LTD. ("we", "us", "our", and their derivatives) provide websites, mobile applications, including GPark, software, platforms, contents, updates, features, experiences, patches, downloadable contents and other online services ("Services"). We respect your privacy rights in different jurisdictions and always take them seriously. This privacy policy ("Policy") describes our practices regarding the collection, use and disclosure of information on, through or in connection with our Services. Please read this entire policy carefully and note that if you do not agree with this policy, you must not use any of our websites, applications, or other online services. By using our Services, you are accepting our rules regarding your personal information as described in this policy.
TABLE OF CONTENTS
1.WHAT INFORMATION DO WE COLLECT?
2.HOW DO WE USE YOUR INFORMATION?
3.WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
4.DATA RETENTION AND SERCURITY
5.YOUR RIGHTS AND CONTROLS
6.CHILDREN
7.THIRD-PARTY SERVICES
8.YOUR PRIVACY RIGHTS IF YOU LIVE IN CALIFORNIA
9.YOUR PRIVACY RIGHTS IF YOU LIVE IN THE EEA, UK OR SWITZERLAND
10.UPDATES TO THIS POLICY
11.CONTACT US
1. WHAT INFORMATION DO WE COLLECT?
We will collect and process the following information about you:
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Source
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Category
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Purpose
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Legal Basis
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Information You Provide to Us
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When you create an account for GPark, we may collect your username, email address, password, birthdate, etc. Please keep in mind that you must not create a username that includes your real name or other personal information. As for the birthdate, we collect it solely for the purpose of verifying your age.
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We use this information to create your account for GPark in accordance with your request.
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It is necessary for the performance of the contract between you and us.
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Id.
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When you contact us or report a problem with our services, we may collect your username, email address, and records and copies of your correspondence.
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We use this information to improve our services, respond to your communications, and provide troubleshooting, such as addressing and remediating technical issues and bugs.
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It is necessary for the performance of the contract between you and us.
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Id.
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When you respond to a survey or questionnaire, we may collect the information provided, for example, your username.
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If you agree to participate in a survey conducted by us, we use this information to improve our services and furnish you with some incentives in some circumstances.
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The legal basis for this processing activity is our legitimate interests in improving our services.
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Id.
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When you make purchases in GPark, we may collect your billing information, such as your name, payment card number, payment account details, etc. We may also retain transaction details and purchase and payment history.
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We use this information to facilitate your payment and maintain a record of your transaction history.
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It is necessary for the performance of the contract between you and us and we also process this information based on our legitimate interests in being able to resolve subsequent billing disputes and inquiries.
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Id.
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When you interact with other players via certain social features in GPark, we may process information regarding such interactions, including timestamps or chat content to monitor, filter and moderate this information for the purposes of being able to remove profanity, personal information, and other inappropriate conversations. Please note that any personal information submitted by you in forums and similar means offered by us is available to anyone who has access to this forum including other users. The personal information posted by you can be read, collected or used by other users of these forums and could be used to send unsolicited messages (although we’ll try our best to filter and/or block them). In some cases, these functionalities may be provided by third parties, in which case we may not have access to the content of such communications.
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We use this information to facilitate certain social features and prevent inappropriate communications.
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The legal basis for this processing activity is our legitimate interests in being able to defend ourselves from possible liability claims that may arise from unlawful posts from you.
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Id.
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When you or a person on behalf of you submit a data subject request, we may collect the country/region, name, user email address, screenshot of user ID and user nickname, user ID, account registration date, login method, user nickname of linked social media account, account balance, request details, and/or any other information necessary to verify your identity, and if the request is made by a requestor on your behalf, name of the requestor, email address of the requestor, the requestor’s relationship with you, and/or proof of your identity and the requestor’s authority.
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We use this information to confirm your and, if applicable, the requestor’s identity, your rights and to process the request.
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It is necessary for the performance of the contract between you and us and we also process this information based on our legitimate interests in fraud prevention as well as data breach prevention.
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Information We Collect Automatically
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Usage Details. When you access and use GPark, we may automatically collect certain details of your access to and use of it, including traffic data, behavioral data, and the resources that you access and use on or through GPark.
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We will process this information to provide you with our services.
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The legal bases for this processing activity are your clear and affirmative consent, and our legitimate interests to enhance the user experience.
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Id.
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Network Information. We may automatically collect some network information when you use our services, e.g., IP address, network quality data, network type, network strength, network speed.
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We use this information to confirm your current network status.
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It is in our legitimate interests to ensure the security of our services and improve our services.
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Id.
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Log Information. We may automatically collect some log information when you use our services, e.g., login log, item log, commodity purchase log, activity log, upgrade log, chat log, online friends, and other logs generated when users use the services.
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We use this information to facilitate certain features of GPark and improve our services.
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It is necessary for the performance of the contract between you and us.
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Id.
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Application Information. To ensure the security of the network and services, we will collect your application information (APK name, version, running time, progress name) and device information (model, OS version, brand, CPU structure, ROOT status, unique identifier of the ROM, screen resolution, system running time, whether the emulator is running, installed APK information, Mac address, network type, name of the running application, SD card application list of file names in the cache directory and WIFI name).
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We use this information to ensure the security of the network and our services.
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The legal basis for this processing activity is our legitimate interests to guarantee the stability and security of our services, show you content that may be more relevant to you and your interests, manage registrations and improve our services.
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Id.
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Cookies. We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (collectively referred to as "Cookies") to enhance your experience using our services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. You have the option to permit installation of such cookies or subsequently disable them. You may choose to accept all cookies, accept part of cookies, or reject all cookies except for the substantial ones. However, blocking some types of cookies may impact your experience of the services we are able to offer.
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We use this information to enhance your experience using our services.
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We will collect and process this information with your explicit consent and based on our legitimate interests in maintaining the normal operation of our services.
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Information We Receive from Third Parties
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Registration via Third Parties. To facilitate your use of GPark, you can log in to this product through some third-party social media platforms, like Google, Facebook or Apple. To achieve the above purposes, we may need to obtain and collect your third-party account information (display name, avatar, user ID, etc.) from third parties. Your privacy settings on the other company’s website or service typically control the specific types of information they can share with us, so please be sure to review and update them regularly.
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We use this information to facilitate your use of GPark.
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It is necessary for the performance of the contract between you and us.
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Id.
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Payment Information. When you make payments in GPark, we receive the following information from our payment providers about your transactions: transaction ID, country, payment provider used, purchased item, currency, value, and payment timestamp.
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We use this information to facilitate your payment, provide you with the details of your transactions and ensure the security of transactions within our services.
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It is necessary for the performance of the contract between you and us to facilitate your payment and provide you with the details of your transactions. We also collect this information based on our legitimate interests to ensure the security of transactions within our services.
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Id.
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Analytics Information. We integrate analytics software from third party analytics providers in GPark. We then receive reports that help us optimize our in-app features and events for each user of GPark, which include your user ID and information on your in-app activity.
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We use this information to improve our services and enhance your experience.
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It is necessary for the performance of the contract between you and us. We also collect this information based on our legitimate interests in improving our services and enhancing the user experience.
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Id.
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Advertising Information. To market our services, inter alia, via social media platforms in order to bring new users to our websites and to maintain and increase our user base, we may process personal information such as IP addresses, information on users’ browsers or operating systems, including language settings, location information and usernames or user IDs. Besides, we will present you with ads and suggestions on our services, contents, features, and elsewhere. These ads and suggestions may be tailored specifically to you ("Personalised Content").
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We use this information to market our services.
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We will collect and process this information with your explicit consent and based on our legitimate interests in monitoring the success of our advertising and marketing programs with this information.
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2. HOW DO WE USE YOUR INFORMATION?
We use the information we collect to help us provide, improve, customize, analyze, and promote our Services. This includes using it for purposes such as:
· To Provide You with Our Services. We will use your information to perform our contractual obligation towards you to allow you to create an account, enjoy numerous experiences in GPark (including as a guest), remember your progress, allow you to play with your friends and communicate with them via in-app chat. We will also use your information to allow you to make purchases via Google Play or Apple App Store and maintain a record of such purchases. The information we process when doing so includes your registration information, information you provide to us when enjoying some experiences, identifiers, information you generate and display when enjoying some experiences, and information regarding your use of GPark.
· To Improve and Personalize Your In-app Experience. We may present content or features better tailored to you or your interests, or our inferences about your interests. For example, if you frequently enjoy experiences in a certain genre, we may infer that you’d be interested in that genre and suggest similar experiences to you.
· To Provide You with Support. If you reach out to us for support, we will use your information to respond to your communications, provide troubleshooting, such as addressing and remediating technical issues and bugs, and improve our Services. When doing so, we perform our contractual obligation towards you. The information we process when doing so includes your registration information, your identifiers, information about your device such as your Wi-Fi strength and the amount of free space on your device, and any other information about you collected via our customer support channels.
· To Conduct Analytics. We use internal and third-party analytics technologies to collect information about how you use our Services, your computer or device and the health of our Services. It is in our legitimate interests to analyse the use of and inform, our products, newsletters and advertising campaigns, and any other interaction or interest in the same. When doing so, we will process information we automatically collect or is generated about you when you use our mobile applications or interact with our newsletters and advertising campaigns to (a) create anonymised and aggregated data; (b) create segments of users who show particular characteristics or interests; and (c) conduct predictive analytics about your interests.
· To Provide You with Advertising. We will present you with ads and suggestions in our experiences and elsewhere. These ads and suggestions may be tailored specifically to you. Where it is required, we will only do so where we have your consent. In situations where your consent is not required, or where we provide contextual advertising, we do so based on our legitimate interests. If you no longer want to receive targeted advertising, you can withdraw your consent in the privacy settings, or if that option is not available, please see Section 5 "Your rights and controls" which explains how you can opt out and change your browser and device settings. To tailor ads and to allow our advertising partners to tailor ads, we process information we automatically collect or is generated about you when you use GPark and information received from third parties.
· To Prevent and Detect Fraud. We strive to provide a safe and fair environment for all users. It is in our legitimate interests to protect our users against online abuse and other anti-social or illegal activity.
· Others. We may also collect and process your personal information to manage, customize, and measure the effectiveness of our surveys, promotional offers, and events; comply with our legal or contractual obligations and enforce our terms; establish, exercise or defend legal claims; track your process across our websites and applications to verify that you are not a bot and to optimize our Services; send you related information like updates, security alerts and support messages; and/or for any other purposes for which we provide specific notice at the time the information is collected. We may also process information that does not identify you individually, including aggregate or de-identified information that we create or collect from other sources. This information helps us better understand larger groups of users. If we combine this information with information that identifies you, we will treat it as described in this privacy policy. But please note that this privacy policy does not restrict our ability to process information that does not individually identify you, and we may use and disclose aggregated or de-identified information for any reason permitted by law.
3. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We may share some of the information we collect to help operate and improve our Services. Depending on how you interact with us, common examples are as follows:
A. Other Users of Our Services
If you use social features such as chat, or you make some information public, such as your display name, content you create or share, basic experience statistics, your profile data, and other similar information may be generally accessible to others, other users of our Services may be able to access some of your personal information.
B. Service Providers
Vendors and other service providers that help us operate our business and provide you with services may receive your personal information. We require that any service provider processing your personal information only do so on our behalf and for purposes consistent with this policy, such as the purposes described in Section 2 "How do we use your information". Besides, we will sign strict data protection agreements with them, requiring them to handle personal information in accordance with our instructions in this privacy policy and any other relevant confidentiality and security measures.
C. Affiliates and Subsidiaries.
We may disclose personal information to other companies in which we have an ownership interest as necessary for the purposes outlined in this policy.
D. Disclosure in the Event of Merger, Sale, or Other Asset Transfer.
Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. Where required by applicable law, you will be informed of such disclosure and your consent obtained.
E. Advertising Partners.
Through our Services, we may allow third-party advertising partners to use technologies and other tracking tools to collect information regarding your use of our Services and your device. We also may share information relating to your device and your use of our Services with our third-party advertising partners, so they may deliver targeted advertisements to you when you visit third-party services and websites within their networks. This practice is commonly referred to as "interest-based advertising", "online behavioral advertising", or "targeted advertising". But prior to the disclosure, we will seek your consent.
GPark adheres to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising (www.AboutAds.info). The Digital Advertising Alliance maintains a website where consumers can opt out of receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).
F. Law Enforcement Agencies, Public Authorities or Other Judicial Bodies and Organisations.
There are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity's request when that governmental entity has not provided the required subpoena, court order, or search warrant.
Please note that we will share your personal information with the following partners/contractors in order to maintain the proper functioning of our current services:
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No.
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Name
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Function
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Privacy Policy
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1
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Firebase
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Analytics services
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2
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Facebook
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Analytics services
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3
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Flurry
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Analytics services
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4
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Google Analytics
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Analytics services
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5
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Google reCaptcha
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Verification
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6
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AppLovin
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Advertisement
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7
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Facebook Audience Network
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Advertisement
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8
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Google AdMob and their partners
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Advertisement
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9
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Google AdSense
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Advertisement
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10
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IronSource
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Advertisement
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11
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MoPub and their partners
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Advertisement
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12
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Pangle
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Advertisement
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13
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Unity Ads
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Advertisement
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14
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Vungle
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Advertisement
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15
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Facebook Analytics
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Analytics services
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16
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Facebook Ads conversion
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Advertisement
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17
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BUGLY
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Analytics Services
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18
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TencentCloud
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Chat
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19
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Agora
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Chat
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4. DATA RETENTION AND SERCURITY
We protect your personal information through a combination of collection, security and retention policies.
· Limited Retention. We only keep your personal information for as long as we need it for business and operational needs or to comply with any statutory, regulatory, or legal obligations. For example, we may retain personal information collected from you to support user inquiries and prevent repeated violations or suspected violations of this policy if your account has been banned or your access to the services has been disabled for any reason. When deleting information, we will take measures to make the information irrecoverable or irreproducible, and electronic files which contain information will be deleted permanently.
· Purpose Limitation. We will use your personal information only for the services you choose to access and for the purposes for which you choose to share it. We will respect your requests to start or stop processing your personal information for marketing purposes, as well as the types of marketing messages you may wish to receive.
· Where We Store Your Information. Due to the nature of our Services, some of your personal information may be transferred to, stored in, and processed by our affiliated companies, subcontractors, service providers, etc. located outside the country where you reside, and our support, engineering and other teams based in different areas may be granted access to your personal data. By accepting this policy, you understand and agree that your information may be processed on servers which shall be located in America and/or Brazil. Please note that different countries may have different personal information protection laws than your own country, but we will try to ensure that adequate safeguards are in place to protect your personal information in this policy.
· Security Measures. We use appropriate measures to ensure a level of security appropriate to the risk involved and have implemented contractual, technical, administrative, and physical security measures designed to protect personal information from unauthorized access, disclosure, use, and modification. As part of our privacy compliance processes, we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in this policy does not guarantee the security of your personal information 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
· Your Practices and Activities. Your practices and activities are likewise very important for the protection of your own personal information. You can take certain steps to help protect your personal information, such as being mindful of what you share publicly in our products and services. For example, (a) do not create a username including your real name or other personal information; (b) do not pick a password that is easy to guess and do not share your password; and (c) do not post anything private about yourself or anyone else in public-facing areas of our Services.
5. YOUR RIGHTS AND CONTROLS
We provide you with choice and control about our use of your information, including your ability to exercise your data privacy rights.
· Access. You can access the personal information we hold about you, including the categories of personal information collected, where we collect it from, why and how we use it, and who may receive this information. This right is not absolute. For example, we cannot reveal trade secrets, or give you information about other individuals. If you believe we hold any other personal information about you, please contact us at privacy@craftsman.sg.
· Correction. You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at privacy@craftsman.sg.
· Erasure. You have the right to request the deletion of personal data concerning you if the reason why we could collect it does not exist anymore or if there is another legal ground for its deletion. As a result of deleting everything in your GPark account, you will lose access to GPark services including your account, related subscription, related information linked to your account, and other services accessed through your account. If there is any other personal information you believe we process that you would like us to erase, please contact us at privacy@craftsman.sg. However, we may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression), but we will let you know if that is the case.
· Objection. According to applicable laws and regulations in your country/region of residence, you may have the right to (a) withdraw your consent where you previously provided such consent; or (b) object to our processing of your information where we process such information on the basis of our legitimate interests described in Section 1 "What information do we collect". If you'd like to exercise your right to object, please contact us at privacy@craftsman.sg. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.
· Portability. You have the right to receive a copy of information we process on the basis of consent or contract in a structured, commonly used and machine-readable format, or to request that such information is transferred to a third party.
· Restriction. Under certain circumstances stipulated by applicable laws and regulations in your country/region of residence, you may have a right to stop us processing your personal information.
6. CHILDREN
Our Services are not intended for children and we do not knowingly collect information from children. By children, we mean users under the age of 13 years old or the age stipulated in applicable laws and regulations in your country/region of residence. Children are not allowed to create any account for our Services, to the extent permitted by applicable law.
If you are a minor over 13 years old but under the legal age of majority ("Minor") as defined by the laws and regulations of your region/country of residence, you must have your parent or guardian read through this policy with you and you represent that you have obtained the permission of your parent or guardian to create a GPark account. What's more, please do not send us or other users any personal information, including without limitation your real name, address, phone number or e-mail address.
We strongly urge parents to supervise children and minors not to disclose personal data without prior parental consent. Minors may use and access our service only with the involvement of a parent or legal guardian.
If you believe that we have unintentionally collected your children’s personal information, you may request the deletion of the information by contacting us at privacy@craftsman.sg. In some cases, we may ask the user to provide us with their date of birth for age verification. If such information indicates the user is under the age stipulated by the applicable laws and deemed as child under such laws, we will not collect further personal information from the child until a parent/guardian’s verifiable consent is obtained.
7. THIRD-PARTY SERVICES
If you access any of our Services through a third-party platform such as Facebook or Google ("Third-Party Services"), you must understand that those Third-Party Services may collect other information about, including information you share with them directly or about your use of our Services, in accordance with their own terms and privacy policies. The privacy practices described in this policy do not apply to Third-Party Services. Any links in GPark to Third-Party Services do not imply that we endorse or have reviewed the Third-Party Services.
8. YOUR PRIVACY RIGHTS IF YOU LIVE IN CALIFORNIA
The California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to: (a) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (b) request deletion of your personal information; (c) opt out of sale of your personal information (if any); and (d) not be discriminated against for exercising these rights.
You or your authorized agent may make these requests by contacting us as described in Section 11 "Contact Us" below. Note that we may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise your rights under the CCPA.
Please note that we have not and do not sell personal information about you to third-party companies for their independent purposes. We do, however, disclose personal information as described in Section 3 "Who we share your personal information with".
9. YOUR PRIVACY RIGHTS IF YOU LIVE IN THE EEA, UK OR SWITZERLAND
If you’re located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed.
A. Data Subject Rights
You may have the right to access, correct, or delete personal data we have collected about you through our Services. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. Where you have provided your consent to our data processing, you have the right to withdraw consent.
You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.
Please note that we do not use your personal information for automated decision-making, which produces legal effects concerning you or similarly significantly affects you.
For more details, please refer to Section 5 "Your rights and controls".
B. Legal Basis
If you are a resident of the EEA, Brazil, Switzerland, or the United Kingdom, we rely on a number of legal bases to process information about you. We will process information about you where we have your consent, where we have a legitimate interest in doing so, where the processing is necessary for the performance of a contract with you, and/or where we have a legal obligation to process your information.
Please refer to Section 1 "What information do we collect", as we have attached the legal bases set out in Article 6(1) GDPR to each category of personal data we collect and process.
C. Data Transfer
When you use our Services, your information may be transferred to or stored in the United States or other countries where we or our service providers operate. The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate, for instance, the standard contractual clauses provided by the European Commission, your explicit and unambiguous consent, being necessary for the performance of the agreement between you and us, etc. If permissible under local law, you’re authorizing us to process your information in any of the locations where we operate by using our Services. If you have questions, please contact us at privacy@craftsman.sg.
10. UPDATES TO THIS POLICY
If we make any material changes to this privacy policy, we will post the updated policy here and notify you in accordance with relevant legal requirements.
11. CONTACT US
To fulfill the requirement stipulated by GDPR, and other data protection laws, CRAFTSMAN TECH PTE. LTD. is the data controller of GPark. If you have questions relating to this privacy policy, wish to make a complaint about how we process your personal data, or exercise your rights as a data subject, please contact our DPO in the first instance at privacy@craftsman.sg and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you consider we have infringed data protection laws.
Last Updated: May 16, 2023