Effective Date: 01. 01, 2023
1. Introduction and Overview
2. Information Collection
3. Use of Information
4. Sharing of Information
5. Other Parties
6. Analytics and Advertising
7. Your Rights and Choices
9. Data Security
10. International Transfer
12. Contact Us
13. Additional Disclosures for Nevada Residents
14. Additional Disclosures for California Residents
15. Additional Disclosures for Data Subjects in Europe
16. Additional Disclosures for Taiwan Citizen or Data Subject in Taiwan
17. Additional Terms for Residents in Japan
18. Additional Disclosures for Data Subjects in Russian Federation
1. Introduction and Overview.
For personal data transferred from the United Kingdom, the European Union or Switzerland, we will provide appropriate safeguards, such as the use of Standard Contractual Clauses.
2. Information Collection.
We collect information about you when you use the Service, including when you use our Games, register an account, access our content, sign up for a rewards program, make a purchase, participate in a promotion, or contact customer support.
- A. Information You Provide to Us.
The categories of information we collect when you use the Services include:
- Contact Data, including your email address, phone number.
- Billing data, including Guardian email address, coupon codes, mobile phone personal authentication information, bank name, and credit card company.
- Demographic data, including your date of birth, gender, and country.
- Commercial or transactions information, including records of products or services purchased, obtained or considered.
- Content that includes any messages you send to us (such as feedback and questions about customer support) or content you post publicly on the Service (such as product reviews or blog comments). We also collect content within any messages you exchange with other users through the Service (such as if you use our chat functionality).
If you participate in a promotion and are declared a winner, depending on the prize, we may also collect your driver’s license number, passport number, or other similar identifiers as set out in the additional terms and conditions of that promotion.
If you are eligible to participate in an Event and receive a gift, we may collect the following in order to provide the gift to you:
- For physical gifts: name, mailing address, phone number, and email address.
- For digital gifts: name, mobile phone number, and email address.
You may choose to voluntarily provide other information that we have not requested, in which case you are solely responsible for such information.
- B. Information Collected Automatically.
In addition, we also collect information automatically when you use the Service. The categories of information we automatically collect include:
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
- Service Use Data, including data about features you use, emails and advertisements you view, gameplay data related to your interactions with our Games, faulty use records, products and services you view and purchase.
- Device Data, including data about the type of device or browser you use, the operating software of your device, your device’s regional and language settings, and device identifiers such as IP address, a Global Unique Identifier, and advertising IDs.
- Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).
The types of tracking technologies we use to collect information automatically include:
- Log Files, which are files that record events that occur in connection with your use of the Service.
- Cookies, which are small data files stored on your device that act as a unique tags to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our websites and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. In addition, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
- App Technologies, which are technologies included in our Apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our Apps may include SDKs (such as the Facebook SDK), which is code that sends information about your usage to our servers. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
- Location Identifying Technologies, which are technologies used to collect your location. For example, GPS, Wi-Fi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our Apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
- C. Information from Other Sources.
We also collect information from other sources. The categories of sources from which we collect information include:
- Social networks with which you interact or use to log into the Platform, Games, or Streaming Services.
- Partners who provide co-branded services, sell or distribute our products, or engage in co-marketing activities.
- Publicly available sources, including data in the public domain.
3. Use of Information.
- Service operation and management.
- Performing services requested by you, such as responding to your comments, questions, and requests, facilitating a refund, and providing customer service.
- Send technical notices, updates, security alerts, information about policy changes, and support and administrative messages.
- Preventing and addressing fraud, policy or terms violations, threats, or damage.
- Monitoring and analyzing trends, usage, and activities.
- Conducting research, including focus groups and surveys.
- Improving the Service and other DONAMIC websites, apps, marketing activities, products and services.
- Developing and sending advertisements, direct marketing, and communications about our and legal entities’ products, offers, promotions, rewards, events, and services.
- Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.
- Fulfilling any other purpose at your direction.
- With notice to you and your consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or anonymized information) for any purpose, except were prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
4. Sharing of Information.
- Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
- Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers or independently decide how to process your information in certain circumstances. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
- Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
- Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
- Promotions and Prizes. Our promotions and prizes may be jointly sponsored or offered by other parties. If you voluntarily participate in a promotion or claim a prize, we will share information as set out in the official rules or additional terms and conditions applicable to the promotion or prize, and for administrative purposes and as required by law (e.g., a list of winners). By participating in a promotion or receiving a prize, you agree to the official rules or additional terms and conditions applicable to that promotion or mission, except were prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
- Public Forums. We share information you disclose through the Service, such as information in your profile or information you post on public bulletin boards. You are solely responsible for any information you disclose, so think carefully before disclosing any information. After posting information, you may not edit or delete it in accordance with the additional rights set forth in the "Your Rights and Choices" section below.
- Mergers or Acquisitions. We share information in connection with or during negotiations in connection with a proposed or actual merger, purchase, sale or other type of acquisition, business combination of all or a portion of our assets, or transfer of all or a portion of our business to another business.
- Security and compulsory disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
- Facilitating Requests. We share information at your request or direction.
- Consent. We share information with notice to you and your consent.
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
5. Other Parties.
We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.
Some examples include:
- Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
- Loggin. We may allow you to log in or create an account through social media or other platforms such as through a Google, Facebook, Apple, Twitter, Line accounts. If you choose to engage with such integration, we may receive information from the platform that you have authorized to share with us, such as your public profile name, email address, and internal identification information. Please note that the platform may independently collect information about you through the integration.
6. Analytics and Advertising.
We use analytics services to help us understand how users’ access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may integrate tracking technologies into our own Service (including our Websites, Apps and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the various devices you use and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people who are similar like people) who have visited our Service or are identified in one or more of our databases (“matching Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.
For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matching Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
7. Your Rights and Choices.
- A. Account Information.
You may access, update, or remove certain information that you have provided to us through your DONAMIC account by visiting your account settings or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
B. Tracking Technology Choices.
- Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser to reject or delete cookies by changing your browser's settings. If you use multiple browsers on your device, you will need to instruct each browser individually. The ability to restrict cookies may vary depending on your browser settings and restrictions.
- Do Not Track. You can automatically send "Do Not Track" signals to online services you visit in your browser settings. Note, however, there is no industry consensus as to what site and app operators should do with regarding these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take an action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
- App and location technologies. You can uninstall the app to stop collecting all information through the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an App by uninstalling the App or withdrawing your consent through your device settings.
Please be aware that if you disable or remove tracking technologies some parts of the Service may not function properly.
C. Analytics and Interest-Based Advertising.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
To opt out of us using your hashed email for matching Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of matching ads. We will stop sharing such information for matching Ads.
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding them opt out options or programs.
- E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
- Push Notifications. If you choose to receive push notifications on your device, you can opt out at any time by adjusting your device's permissions or by removing the app.
- Text Messages and Calls. You can opt-out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of text messages; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set out in the “Contact Us” section below and specifying you want to opt-out of calls.
Please note that you opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
The Services are intended for the general public and are not directed at children under the age of 13. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If we become aware we have collected personal information in violation of COPPA, we will remove the personal information in accordance with COPPA. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.
If you are a California resident under 18 years old and registered to use the Service, we may ask you to remove any content or information you have posted on the Services. To make a request, please let us know what you want to remove by sending an email to the email address specified in the "Contact Us" section with "California Under 18 Content Removal Request" in the subject line. We cannot guarantee complete or comprehensive removal of the Content and may retain the Content as necessary to comply with our legal obligations, resolve disputes, and enforce our Agreements, but we will use reasonably good faith efforts to remove the Content from potential public view.
9. Data Security.
We implement and maintain reasonable administrative, physical and technical security safeguards to protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission over the Internet is not completely secure and the security of information about you cannot be guaranteed.
10. International Transfer.
12. Contact Us.
By email: firstname.lastname@example.org
By mail: 2Floor. 14-8, Teheran-ro 78-gil, Gangnam-gu, Seoul, Republic of Korea
13. Additional Disclosures for Nevada Residents.
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at email@example.com
14. Additional Disclosures for California Residents.
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
- A. Notice of Collection.
In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:
For further information about the information we collect, including the sources from which we receive information, review the “Information Collection” section above. We collect and use these categories of personal information for the business purposes described in the “Use of Information” section above, including to manage our Service.
- Identifiers, including name, postal address, email address, phone number, online identifiers (such as IP address), driver’s license number, passport number, or other similar identifiers.
- Customer records.
- Characteristics of protected classifications under California or federal law, including gender, date of birth, and country of residence.
- Commercial or transactions information, including records of rewards, promotions, products or services entered, purchased, obtained, or considered.
- Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
- Geolocation data.
- Inferences drawn from the above information about your predicted characteristics and preferences.
B. Right to Know and Delete.
You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
In addition, you have the right to delete the personal information we have collected from you.
To exercise any of these rights, please submit a request at firstname.lastname@example.org In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may reject your unknown or deletion request.
C. Right to Opt-Out.
To the extent DONAMIC sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to emailing us at email@example.com.
D. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
F. Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
15. Additional Disclosures for Data Subjects in Europe.
- A. Roles.
Data protection laws in Europe, distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). DONAMIC acts as a controller with respect to personal data collected as you interact with emails, and advertisements.
- B. Legal Basis for Processing.
Data protection laws in Europe require a “legal basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
C. Your Data Subject Rights.
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.
Please note that we retain information as necessary to fulfil the purposes for which it was collected and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you may contact us as set out in the “Contact Us” section above.
16. Additional Disclosures for Taiwan Citizen or Data Subject in Taiwan
These additional disclosures apply only to Taiwan citizens or data subjects as defined under Taiwan law.
- A. Your Data Subject Rights.
Taiwan’s Personal Data Protection Act (“PDPA”) provides the following rights to Taiwan citizens and data subjects in Taiwan:
We may charge a fee for providing access to your personal data. To exercise any of these rights, please submit a request to firstname.lastname@example.org.
- Right to make an inquiry of and to review your personal data;
- Right to ask us for a copy of your personal data;
- Right to correct or supplement your personal data;
- Right to demand the cessation of collection, processing or use of your personal data; and
- Right to delete your personal data.
- B. Retention Period for Your Personal Data
We process and use the information we collect in the manner set out under the “Information Collection” section above for a period that is necessary to achieve the purposes set out under “Use of Information” section.
- C. Territory in Which Your Personal Data Will Be Used
We process and use the information we collect in the manner set out under the “Information Collection” section above in the territory where the parties provided in the “Sharing of Information” section are located and any other territory that is necessary to achieve the purposes set out under the “Use of Information” section.
- D. Consequences of Not Providing Your Personal Data
If you choose not to provide your personal data to us, you may not be able to use some parts of or the entire Service. You may also be unable to receive or use some or all the products, services, or promotional offers provided by us via use of the Service.
17. Additional Terms for Residents in Japan.
- A. Parental Consent
- B. Sensitive Information
We do not collect or provide to third parties any "personal information requiring special attention" about you, including race, creed, social status, medical history, criminal record, facts of harm caused by crime, physical, intellectual or mental disability, results of medical examinations or other tests, or instructions for improving your mental and physical condition without your consent. or medical or prescription, arrest, search, seizure, detention, prosecuting authority or other proceedings relating to criminal cases, or other proceedings relating to investigations, observation and protective measures, hearings and decisions, protective measures, or juvenile protection cases.
- C. International Transfer
When we share your information in accordance with Section 4, the information about you may be transferred to, or processed, stored, and used by third parties in jurisdictions outside Japan, including the U.S., Korea, Singapore, Hong Kong, Thailand, Philippines, Indonesia and Russia. Your use of the Service or provision of any information constitutes your consent to the transfer to and, processing, usage, sharing, and storage of information about you by such third parties in other jurisdictions. If you do not agree to transfer to, or processing, usage, sharing, and storage of information about you by such third parties in other jurisdictions, please refrain from using the Service or providing information about you.
18. Additional Disclosures for Data Subjects in Russian Federation
- A. Definitions.
- “Personal data” any information relating to a directly or indirectly identified or identifiable individual (personal data subject);
- “Processing of personal data” any action (operation) or a set of actions (operations) performed with or without the use of automation with personal data, including the collection, recording, systematization, accumulation, storage, specification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data;
- “DONAMIC”, “Operator” DONAMIC CORPORATION being the operator of personal data;
- B. Purposes of personal data collection.
- C. Legal basis for processing of personal data.
DONAMIC processes Users' personal data on the following legal grounds:
- Execution of a contract – the Terms of Service and End User License Agreement to which the User is a party;
- Consent to the processing of personal data (for example, when the User has checked the box on the consent to the processing of personal data contained in the interactive forms);
- Processing of the User's personal data is necessary to perform the duties, functions, powers entrusted to DONAMIC by the legislation.
- Processing of the User’s personal data is necessary to effect rights and legal interests of the DONAMIC or third parties, or to achieve publicly significant goals, provided that the User’s rights and freedoms are not violated.
- D. Procedure and conditions of personal data processing.
(a) the list of actions performed by the operator with personal data of users: collection, recording, systematization, accumulation, storage, specification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data.
(b) How DONAMIC processes personal data: automated, blended, non-automated.
If any inaccuracy of the Personal Data is identified, DONAMIC, will ensure that the Personal Data is updated.
- A. Retention Period for Your Personal Data
We process and use the personal data we collect in the manner set out under the “Information Collection” section above for a period that is necessary to achieve the purposes set out under “Use of Information” section.
- B. Conditions for the termination of personal data processing.
The processing of personal data ceases if at least one of the following conditions is met:
- User has unilaterally withdrawn from the Terms of Service and End User License Agreement;
- The User has withdrawn his consent to the processing of personal data;
- The predetermined purpose of processing personal data has been achieved;
- The period of validity of the consent to the processing of personal data has expired;
- Unauthorized processing of personal data was detected.
- C. Rights of the User as a subject of personal data.
The User has the right to receive his/her personal data for familiarity and to request correction, blocking or destruction from DONAMIC if it is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purposes of processing. In addition, the User has the right to receive information relating to the processing of personal data. You have the right to protect your rights and legitimate interests in court, including compensation for losses and/or compensation for moral damage.
Users may refuse to process their personal data at any time by contacting DONAMIC through any of the communication channels listed in the "Contact Us" section.