Privacy Policy
Last Updated: [June 29th, 2020]
New Leaf Inc.
and its affiliates (“New Leaf”, “us”, “our” or “we”) are dedicated to
protecting the privacy rights of our users (“users” or “you”). This Privacy
Policy (the “Policy”) describes the ways we collect, store, use, and manage the
information, including personal information, that you provide or that we
collect in connection with our websites that link to the Policy or any New Leaf
mobile application or game (available for example on iOS and Android)
(collectively, the “Services”) and the privacy rights available to you..
Please note this Policy only applies to information
collected or received by New Leaf through your use of the Services. It does not
apply to, and New Leaf is not responsible for, the actions of third party people or companies, the content of their sites,
their use of information you provide to them, or any products or services they
may offer. Any link to those sites does not constitute our sponsorship of,
endorsement of, or affiliation with, those people or companies.
By using the Services, you confirm you have read and
understand this Policy and the processing of your personal information, in the
manner provided in this Policy.
If you have any
questions about this Policy or do not see your concerns addressed here, please
contact us by email at
Information We Collect From
or About You
New Leaf collects information about you as described
below. As set out below in more detail, we use and in specific cases combine
that information to operate, tailor content, personalize and adjust and improve
our Services, and to send you messages or personalized information about our
games, your scores, new features and more, including for marketing and
promotional purposes in accordance with your preferences.
Information
You Give Us: When
you register for and/or use our Services (for example, when you create an
account to access our Services, populate your in-app profile, communicate with
other users of our Services (e.g. through in-game chat or forum posts), contact
our customer service or participate in any sweepstakes, contests or promotion),
we collect and store any information that you give us. This information may
also include information you provide through single-sign-on processes (such as
through Facebook), including account name or account number (e.g.
your userID), email address or other identifiers
needed to link your online account with our Services.
Creation
of a New Leaf account.
We will collect certain information from you during the registration/ sign-up
process for the Services. This may include information like your name, locale,
phone number, or email address.
Your
content. Our Services
may allow you to create, upload or share content such as text, images, audio,
your profile information (such as your avatar name and appearance) or other
content you create when you play our games or otherwise use our Services,
Facebook
Connect, Game Center, and Google+: You may be able to log in to our Services using sign-in
services (“Social Login”) such as Facebook Connect, Apple’s Game Center, or an
Open ID provider. These third party Social Login platforms
will authenticate your identity and provide you the option to share certain
personal information with us such as your name or email address to pre-populate
our sign up form. Social Login platforms like Facebook Connect give you the
option to post information about your activities on our Services to your
profile page on such Social Login platform to share with others within your
network.
We may collect and record information through the
relevant Social Login platform in accordance with the policies and terms of
that Social Login platform. The information we collect when you connect your
user account to a Social Login platform may include: (1) your name, (2) your
Social Login's user identification number and/or user name, (3) locale, city,
state and country, (4) sex, (5) birth date, (6) email address, (7) profile
picture or its URL, and (8) the Social Login's user identification numbers for
your friends that are also connected to New Leaf game(s).
Invite
a Friend: New Leaf may
offer you the opportunity to invite your contacts from a Social Login platform
(such as your Facebook friends) so that those contacts can be
located in New Leaf games and/or you can invite them to join you in our
games. Such contact information will be used only for the purpose of sending
the invitation to the addressee(s).
Interaction
with Customer Service: We
may collect your email address and any other personal information you provide
to us when you contact our customer service or otherwise communicate with us.
Forums,
Sweepstakes, Contests and Surveys: We may also acquire information from you through (1)
your access and participation in forums or in game chats on the Services, or
(2) your participation in surveys regarding the Services. We may also provide
you the opportunity to participate in a sweepstakes or contest through our
Service. If you participate, we will request certain personal information from
you. Participation in these sweepstakes and contests are voluntary and you
therefore have a choice whether or not to disclose
this information. The requested information typically includes your contact
information (such as name and shipping address), and demographic information
(such as zip code or equivalent). We use this information to administer the
sweepstakes or contest and to notify winners and award prizes. We may use a third party service provider to conduct these sweepstakes or
contests; in such case, that company is prohibited from using your personal
information for any other purpose.
Information
Collected Automatically:
When you interact with or use our Services, we automatically collect certain
information about your device and your use of our Services. This could include
information such as your, browser type and language, IP address, device ID,
hardware and software information, advertising ID, gameplay data, standard
sever log information, your connections and interactions with other users,
purchase histories with us and social media data (if you have linked your
account and in accordance with your sharing permissions). We (or the third
parties we work with) use standard tracking technologies (like log files,
software development kits (SDKs) and web beacons) to do this. In addition, we
or our partners may also use tracking technologies and advertising IDs to serve
personalized ads to you in our Services. Please see the section below relating
to Tracking Technologies [INSERT LINK TO COOKIES AND SIMILAR TECHNOLOGIES
SECTION] for more details.
Mobile
Platforms: When you play
or otherwise use any of our mobile games or applications, we or third party
partners will collect and process certain information about you, including your
unique device ID (persistent / non-persistent), hardware type, device maker,
media access control (“MAC”) address, international mobile equipment identity
(“IMEI”), the type and version of your operating system (“OS”), language of the
OS, your unique device ID, your time zone, the screen size of your device,
mobile device Advertising ID (known as “IDFA” for iOS devices, or “Android
Advertising ID” for Android devices), your general geolocation information
(city/country based on your Internet Protocol (“IP”) address) and your email
address (if you have connected to Facebook or Google+). This information is
useful to us for troubleshooting and helps us understand usage trends so that
we can improve and personalize the Services for our users. Device identifier /
information such as device type, hardware model, device maker, device operating
system and its language or other technical data like screen size, or
combination of this data, is also collected and used to determine device
compatibility and optimal settings. We may also share this information with our
advertising partners to enable the technical delivery of personalized ads to
your device, as further described below [LINK TO INTEREST BASED ADVERTISING
SECTION].
User
ID: When you
register to use the Services, we create a unique user ID to track your use of
our Services. Specifically, this unique user ID is stored in connection with
your profile information to track the New Leaf games you are playing.
Game
Data Collection: We
collect gameplay information about how you use and play our games. For example,
we automatically collect data such as your game session time, your in-game
interactions (including with other players, where applicable), in-app purchases
that you may make, resource events such as the acquisition or spend of in-game
virtual currencies by you, progression events that are used to mark your
progress or movement within the game (e.g. achievements) and install
timestamps. This information may be associated with your user ID, IP address or
device ID for the purpose of providing you our Services and improving and
personalizing them, or to make inferences regarding your preferences,
predispositions, behavior, abilities and aptitudes.
With your consent, we will also collect your exact or precise location so that
we are able to match you with other players in your area.
Mobile
Analytics: Like
most mobile applications, we use mobile analytics tools to collect certain
information about your usage of our mobile applications and games, as well as
on your device and the health of our Services to allow us to better understand
the functionality of our Services on your device and for app optimization
purposes. Such tools may record information such as how often you use the application
or game, feature usage, gameplay and usage statistics, events that occur within
the application or game, aggregated usage and performance data, and where the
application or game was downloaded from (i.e. which
application store).
We do not link the information we store within the
analytics software to any information that personally identifies you within the
mobile application.
Our Use of Tracking Technologies to Collect
Information Automatically
A.
Tracking Technologies
We and our third party partners,
affiliates, or analytics service providers use standard tracking technologies
(like web beacons, SDKs, APIs, scripts and tags) to identify your
computer/device, to “remember” things about your visit or your use of the
Services (such as your preferences or a user name) and to help us understand
things like, what pages and features you use and the games you play.
Such information may be linked to or combined with other
personal information we process about you, such as your user ID, for purposes
such as improving the quality of our Services, tailoring recommendations to
your interests, providing and personalizing our
Services including making our Services easier to use, and for fraud prevention,
security and authentication purposes.
Please refer to guidance provided by your device
manufacturer, operating system developer, or individual web browser if you
would like help in managing your preferences with respect to tracking
technologies used on our Services.
B.
Interest-Based Advertising
Some of our Services employ ad-serving technologies that
use cookies, clear GIFs, web beacons, tracking pixels, and other similar
technologies to deliver interest-based advertising to you about third party products and services. We may via our third party advertising partners, also advertise our
Services to you on third parties’ websites. You may also see our games
advertised in other services (like on Facebook). After clicking on one of these
advertisements and installing our game, you will become a user of our Services.
When you play our games or otherwise use our apps, some third party tools (SDKs) integrated within our Services may
collect and use certain information collected from your device for the purpose
of ad display and optimization. Such information includes GAID (Google
Advertising ID on Android devices) or IDFA (Identifier for Advertising on iOS
devices), region (i.e. the location where a given
language is used), geo-location information (with your consent) and IP address.
This Policy does not govern our third-party advertising partners, as they have
their own privacy policies, which are accessible using the links provided
below. We have no access to or control over such third parties. In addition to
identifiers, these third parties may also collect information relating to:
·
Advertisements served and the
location of the ad;
·
Length of time an advertisement was visible;
·
Domain type, IP address, size of the
advertisement; and
·
Click-throughs (i.e.
whether a click was made on the ad) and advertisement response.
They use this information (alone or in combination with
information they have collected about you when you use third party websites or
services) to: (i) enable the technical delivery of
ads to your device and to verify click-throughs and/or installs; (ii) provide
you with more relevant ads about our Services (for example, to present you with
an offer for one of our games you might enjoy); (iii) enable offer walls, which
allow you to choose from various rewarded ad or market research offers; (iv)
track results and measure the effectiveness of ads; and (iv) improve the
accuracy of their targeting and measurement systems. We recommend that you
review our advertising partners' privacy policies for more information, further
details of which are set out below:
·
Tapjoy: https://www.tapjoy.com/legal/publishers/privacy-policy/
·
Tenjin: https://www.tenjin.io/privacy/
·
Vungle: http://vungle.com/privacy/
·
Unityads: https://unity3d.com/legal/privacy-policy
·
Adcolony
- https://www.adcolony.com/privacy-policy/
·
Mopub
- https://www.mopub.com/legal/privacy/
·
Gameanalytics
- https://gameanalytics.com/privacy
You can learn more about ad serving companies and the
options available to limit their collection and use of your information by
visiting the websites for the Network Advertising Initiative and
the Digital Advertising Alliance, and the webpages for Facebook's ad
preferences tool and privacy policy. Similarly, you can learn about
your options to opt-out of mobile app tracking by certain advertising networks
through your device settings and by resetting the advertiser ID on your Apple
or Android device. For more information about how to change these settings go
to:
·
Apple: https://support.google.com/ads/answer/2662922
·
Android: https://support.google.com/ads/answer/2662922
·
Windows: http://choice.microsoft.com/en-US/opt-out
Please note: adjusting your
preferences as described in this section does not mean you will no longer
receive advertisements, it only means the ads you do see will be less relevant
to your interests. Our advertising partners will also still use your device’s
advertising ID to serve you with ads that may be less relevant to you; for
example, we may use this for frequency capping (in other words, to control the
maximum number of times you see the same ad from us). You may also reset the
Advertising ID associated with your device by following instructions provided
by your device manufacturer or operating system developer.
C.
Analytics Technologies
We use our own game servers and third
party analytic technologies to collect information about how you use our
Services, your computer or device and the health of our Services.
For instance, we
use Google Analytics, a web analytics service provided by Google, Inc. (1600
Amphitheatre Parkway, Mountain View, CA 94043, USA), on our Services. Google
Analytics uses cookies or other tracking technologies to help us analyze how
users interact with and use the Services, compile reports on the Services’
activity, and provide other services related to our Services’ activity and
usage. The technologies used by Google may collect information such as your IP
address, time of visit and whether you are a return visitor. The Services do
not use Google Analytics to gather information that personally identifies you.
The information generated by Google Analytics will be transmitted to and stored
by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to
learn how to opt out of tracking of analytics by Google, click here.
For our mobile
apps and games on iOS and Android, we use the services of Adjust GmbH (Saarbrücker Str. 37a, 10405 Berlin, Germany). We use the
Adjust SDK (Software Development Kit) which is an analytics service that
provides us the ability to obtain and collect statistical data on the usage of
our games and apps so that we can better understand how our users are using our
games and apps. For this purpose, Adjust processes mobile identifiers such as
the IDFA, GAID or similar mobile identifiers. Adjust's
privacy policy is available here.
Your browser or device may include “Do Not Track”
functionality. Because there is not yet a common understanding of how to
interpret Do Not Track signals, we do not currently respond to "Do Not
Track" signals. However, we provide you with the ability to opt-out of the
use of tracking technologies to send you interest-based advertising as
explained above.
How We Use Information
We use information collected through our Services, both
individually and combined together, for purposes
described in this Policy or disclosed to you in connection with our Services.
For example, we may use your information to:
·
Create user accounts and allow users
to play our games and use our mobile applications;
·
Identify and suggest connections
with other users of our Services;
·
Understand you and your preferences
to enhance and personalize your experiences and enjoyment using our Service;
·
Provide you with personalized
recommendations for mobile applications and games and/or Services;
·
Respond to your comments and
questions and provide customer service;
·
Provide and deliver products and
services you request;
·
Measure the health of our Services;
·
Set up and maintain accounts you
register for;
·
Identify, fix and troubleshoot bugs
and Service or functionality errors;
·
Activate or authenticate your mobile
applications and games and save in-game progress and stats (e.g.
achievements);
·
Run competitions and contests;
·
Survey your opinions through surveys
or questionnaires;
·
Serve and measure the effectiveness
of advertising;
·
Send you service-related
information, including confirmations, invoices, technical notices, updates,
security alerts, and support and administrative messages;
·
Personalizing advertising for you;
·
Communicating with you via email
about promotions, rewards, upcoming events, and other news about products and
services offered by New Leaf and our selected partners, in accordance with your
marketing preferences. If you no longer wish to receive marketing or
promotional communications from us, you may opt-out at any time by emailing us
at rasmussenlayton1995@gmail.com or by using the
unsubscribe options in the email;
·
Enable you to communicate with other
users;
·
Personalize content and experiences
on our Services, including providing you reports, recommendations and feedback
based on your preferences;
·
Optimize or improve our products,
services and operations;
·
Facilitate software updates and
automatically update the software on your device;
·
Protect the integrity of the
Services and enforce our Terms of Service and other applicable terms, including
to detect and prevent fraud and unauthorized activities, to secure our systems
and the Services, to prevent hacking, cheats and spamming and generally to keep
our Services safe and fair and to detect, investigate, and prevent activities
that may violate our policies or be illegal;
·
Detect security incidents, protect
against malicious, deceptive, fraudulent or illegal activity, and prosecute
those responsible for that activity;
·
Perform statistical, demographic,
and marketing analyses of users of the Services.
We may use information we collect from or about you to
create aggregated or de-identified data that does not specifically identify
you.
Push
Notifications: With
your consent in accordance with your device settings, we may send you push
notifications through our mobile applications to send you game or app updates,
high scores and other service related notifications
that may be of importance to you. You may at any time opt-out from receiving
these types of communications by turning them off at the device level through
your settings.
How We Disclose Your Information
New Leaf does not share your personal information except
as approved by you or as otherwise described in this Policy. We may disclose
your information in the following circumstances.
·
With your consent: We
may share your personal information with certain third parties with your
approval and consent.
·
Service Providers: We
engage other companies and individuals to perform services on our behalf for
the purposes described in this Policy. Examples of these services include
analyzing data, IT and related services, payment processing, sending emails and
providing customer support, and security fraud-detection services. These agents
and service providers may have access to your personal information in
connection with the performance of services for New Leaf and are contractually
obligated to maintain the confidentiality and security of your personal
information. We also require that they only use the data on our behalf and for
purposes consistent with this Policy.
·
Third Party Plug-ins: With
third party applications and platforms, such as Facebook Connect, that give you
the option to post information about your activities on our websites and games
to your profile page to share with others within your network. This Policy does
not apply to your use of any such third party
applications and services, and we are not responsible for how those third
parties collect, use and disclose your information. We encourage you to review
the privacy policies of those third parties before connecting to or using their
applications or services to learn more about their information and privacy
practices.
·
Other Users:When
you participate in multiplayer games, your in-game profile, avatar, game play
and statistics will be visible to all. Also, if you participate in social
features, such as chat, the audio, visual, and electronic information that you
disclose may become publically available. It may also
be read, copied, collected, or used by other players. Please make sure your
privacy settings reflect your preferences.
·
Disclosures to protect us or others: We
may release your information as required by law, such as to comply with a
subpoena, or when we believe that release is appropriate to comply with the
law; investigate fraud, respond to a government request, enforce
or apply our rights; or protect the rights, property, and safety of us or our
users, or others. This includes exchanging information with other companies and
organizations for fraud protection.
·
Disclosures in the event of merger, sale or asset transfer: We may share your information
in connection with any merger, sale of our assets, or a financing or
acquisition of all or a portion of our business to another company. You will be
notified via email and/or a notice on our Services of any change in ownership
or use of your personal information.
·
Affiliates:We
may share personal information with our affiliated companies.
·
Advertising Partners: Through
our Services, we may allow third-party advertising partners to set technologies
and other tracking tools to collect information regarding your use of the
Services and your devices as further described in the Interest Based
Advertising section above.
Other Important Information
Changes to the Policy
We may update this Policy from time to time to reflect
changes to our information practices. If we make any material changes we will notify you by email (sent to the email
address specified in your account) or by means of a notice on the Services
prior to the change becoming effective. If we are required by applicable data
protection laws to give you enhanced notice or seek your consent to any such
changes, we will do so. You can see when this policy was last updated by
checking the "last updated" date displayed at the top of this Policy.
We encourage you to periodically review this page for the latest information on
our privacy practices.
Security
New Leaf takes reasonable and appropriate measures to
protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good
faith efforts to store the information collected on the Service in a secure
operating environment that is not available to the public, we cannot guarantee
the absolute security of that information during its transmission or its
storage on our systems. Further, while we attempt to ensure the integrity and
security of our network and systems, we cannot guarantee that our security
measures will prevent third parties from illegally obtaining access to this
information. We do not warrant or represent that your information will be
protected against, loss, misuse, or alteration by third parties. No method of
transmission over the Internet, or method of electronic storage, is 100%
secure, however. Therefore, we cannot guarantee its absolute security.
Data Retention
We will retain
your information for as long as your account is active or as needed to provide
you with our Services. If you wish to cancel your account or request that we no
longer use your information to provide you services, contact us at rasmussenlayton1995@gmail.com.
Notwithstanding the foregoing, we will retain and use your information as
necessary to comply with our legal obligations, resolved disputes, and enforce
our agreements.
Delete Account
Makeover Date: Makeup ASMR --- Performing an account deletion operation in the Makeover Date app is irreversible, so please proceed with caution. Once you initiate the account deletion, your data will be immediately erased, and you will be logged out of the application. The following are the operation steps and notices for account deletion.
Our Policy Regarding Children
We do not knowingly collect or solicit personal
information from a child under the age of 13 (or the age of majority in your
jurisdiction of residence), nor do we knowingly allow children to use our
Service. If you are a child under 13 (or the age of majority in your
jurisdiction of residence), please do not send any information about yourself
to us, including your name, address, telephone number, or email address. No one
under the age of 13 may provide any personal information. If you believe that
we have collected personal information from a child, please contact us using
the contact details as set forth below. In the event that
we learn that we have collected personal information from a child, we will
delete that information as soon as commercially practicable.
International Transfers
We may transfer information that we collect about you to
affiliated entities, or other third parties across borders and from your
country or jurisdiction to other countries or jurisdictions around the world.
Please note that these countries and jurisdictions may not have the same data
protection laws as your own jurisdiction, and we take steps to ensure adequate
safeguards are in place to enable transfer of information to the U.S. and
elsewhere and the use and disclosure of information about you, including
personal information, as described in this Policy.
Your Privacy Choices
Your Choices About Information
Provided by You
If you do not want to provide New Leaf with personal
information, then you can choose not to provide it. If you choose not to
provide us with personal information, we may not always be able to provide you
with the Services you want. For example, without providing an email address,
you cannot create an account with us to access and play our games.
Your Choices About Information
Provided by Third Parties
You may be able to control how third parties collect and
share your Information by changing your preferences or opting out of collection
directly with those third parties. Before disclosing Information to third
parties, we recommend you check their respective privacy policies for further
details.
Your
Marketing and Advertising Choices
You can exercise choices over how we use your personal
information and update your preferences at any time:
·
To remove yourself from individual
contests or promotions, or to opt-out from receiving marketing communications
from us, simply click the unsubscribe link in the email or emailing us at rasmussenlayton1995@gmail.com.
If you opt-out of receiving email marketing communications from us, please note
we may still contact you occasionally about the status of your account, such as
to inform you that your account may be expiring, or for other service related information.
·
To disable selected tracking
technologies from collecting information relating to the effectiveness of
advertising campaigns or analytics data and from serving you with personalized
advertising on our Services, please see the Tracking Technologies section
above.
Accessing and Deleting Your
Information
You may
deactivate your New Leaf account or delete email associate with your account by
contacting us at rasmussenlayton1995@gmail.com
If you would
like to access or view the personal information we
hold about you or for any reason you are concerned with the way we are using
your personal information, or would like to correct or request that we delete
such personal information, you can also send your request to us at rasmussenlayton1995@gmail.com
If you are a California resident or a user in the
European Economic Area (“EEA”), UK or Switzerland and would like to know more
about your rights in connection with your personal information, please see the
relevant sections below.
Additional Information for
California Residents
If you are a California resident, the following
information also applies to you and supplements the information contained in
the Policy in relation to your use of our Services.
Information We Collect and Sources
of Information
Our Policy already describes the information we collect
and the sources of information – see the above section "Information We
Collect From or About You". This section
organizes that information around the personal information categories set out
in the California Consumer Privacy Act (CCPA).
In the past 12 months, we have collected the following
information for the following purposes:
·
Identifiers: This
includes, for example, your name, email address, postal address, Internet
Protocol address, unique personal identifier, account username or screen name,
third party account names and other online identifiers. We obtain this
information when you provide it to us or otherwise automatically in the course of your interactions with our Services.
·
Internet or other electronic network
activity information: This includes, for example, browser
type, and language, device and hardware information, gameplay data, and other
information regarding your interactions with our Services. We obtain this
information automatically in the course of your
interactions with our Services.
·
Demographic information / Protected
Classification Characteristics: This includes
information such as age and gender. We obtain this information when you provide
it to us or otherwise automatically in the course of
your interactions with our Services.
·
Commercial Information: This
includes records of products purchased or considered, or other similar
consuming histories or tendencies. This allows us to provide technical
functionality, develop new products and services, and analyze your use of them.
We obtain this information directly from you or otherwise automatically in the course of your interactions with our Services.
Geo-location data: This includes, for example, your locale, zip code, and
general geolocation
·
Geo-location data This
includes, for example, your locale, zip code, and general geolocation
information (based on your IP address). We obtain this information when you
provide it to us or otherwise automatically in the course of
your interactions with our Services.
·
Audio, Video
and other Electronic Data: This includes audio,
electronic, visual or similar information such as chat and any interaction that
you may have with us (such as for customer service purposes) or with other
players, such as photos, videos, audio, any information you submit in forums,
chat or message boards, and feedback or testimonials you provide about our
Services. We obtain this information when you provide it to us or otherwise
automatically in the course of your interactions with
our Services.
·
Profiles and Inferences: This
includes inferences drawn from any of the information identified above to
create a profile reflecting preferences, characteristics, predispositions,
behavior, attitudes, intelligence, abilities, and aptitudes. We obtain this
information automatically in the course of your
interactions with our Services.
This includes inferences drawn from any of the
information identified above to create a profile reflecting preferences,
characteristics, predispositions, behavior, attitudes, intelligence, abilities,
and aptitudes. We obtain this information automatically in
the course of your interactions with our Services.
How We Use and Share Information
We collect and use personal information for the business
and commercial purposes as described in the section "How We Use
Information" above.
New Leaf does not share your personal information except
as approved by you or as otherwise described in this Policy. You can find more
information in the section “How We Disclose Your Information” above. In the
preceding 12 months, we have disclosed the following categories of personal
information for a business purpose:
o
oIdentifiers
such as those set forth above;
o
oInternet
or other electronic network activity information;
o
oDemographic
information / Protected Classification Characteristics;
o
oCommercial
Information;
o
Geo-location data;
o
oAudio,
Video and other Electronic Data; and
o
oProfiles
and Inferences.
We do not sell personal information about our users or
players. However, we permit certain third party
advertising and analytics partners to collect information about consumers
through our Services for purposes of serving ads that are more relevant, for ad
campaign measurement and analytics, and for ad fraud detection and reporting.
The information collected by our partners include GAID (Google Advertising ID
on Android devices) or IDFA (Identifier for Advertising on iOS devices), region
(i.e. the location where a given language is used),
geo-location information (with your consent) and IP address. For more
information or to opt out of the use of your data for advertising purposes,
please see the section on 'Interest-Based Advertising' above.
Your Privacy Rights
Under the CCPA, California residents have the following
rights:
·
Right to Know: You
have the right to request that we disclose to you the personal information we
have collected, used and disclosed over the past 12 months, and information
about our data practices;
·
Right to Request Deletion: You
have the right to request that we delete your personal information that we have
collected from you;
·
Right to Non-Discrimination: :
We will not discriminate against you for exercising any of these rights.
·
Right to Opt-Out of Sales: We
do not sell personal information, so we do not have an opt-out.
·
Right to be Notified of Financial Incentives:You have the right to be
notified of any financial incentives offers and their material terms, the right
to opt-out of such incentives at any time, and may not be included in such
incentives without their prior informed opt-in consent. We do not offer any
such incentives at this time.
California law also permits you to request certain
information regarding the disclosure of your personal information by us and our
related companies to third parties for the third parties’ direct marketing
purposes. We do not disclose your personal information to third parties for
their own direct marketing purposes.
Because there is not yet a common understanding of how to
interpret Do Not Track signals, we do not currently respond to "Do Not
Track" signals. However, we provide you with the ability to opt-out of the
use of tracking technologies to send you interest-based advertising as
explained above.
To exercise any
of the above rights, or if you are an agent authorized to exercise a right
under the CCPA, you can email rasmussenlayton1995@gmail.com or contact us by mail at the address
provided below.
Please note that to protect your information, we may need
to verify your identity before processing your request. In some cases, we may
need to collect additional information to verify your identity, such as a
government issued ID.
Under the CCPA,
you may exercise these rights yourself or you may designate an authorized agent
to make these requests on your behalf. We may request that your authorized
agent have written permission from you to make requests on your behalf and may
need to verify your authorized agent’s identity. For more information about our
privacy practices, you may email rasmussenlayton1995@gmail.com or contact us by mail at the address
provided below.
Additional Information For Users In The European Economic Area (EEA), The United
Kingdom And Switzerland
If you are a resident of the EEA, the UK or Switzerland,
the following information applies with respect to personal data collected
through your use of our Services.
Data Controller
New Leaf, Inc. is the data controller of your personal
data.
Legal Basis for Processing Your
Personal Data
We collect, use and share your
personal data on the basis of the following:
·
Performance of Contract: We
process your personal data as necessary to perform our contract with you to
provide the Services including to:
·
administer your account with us;
·
provide contests or promotions in
which you have enrolled;
·
support purchases you make;
·
support game functionality; or
·
provide customer support.
·
Consent: We
process your personal data based on your consent. This includes, for example,
providing:
·
newsletters, direct e-mails and
surveys about our Services;
·
targeted ads in our mobile games;
and
·
certain other marketing features.
·
Legitimate Interest:We
process your personal data where we have a legitimate interest to do so and
where those interests do not override your fundamental rights and freedoms
related to data privacy. This includes, for example, processing:
·
to provide you with requested
customer service or technical support;
·
to debug and improve our current and
future Services;
·
in order to
give you exclusive content, personalize your gaming experience with us and
contact you in accordance with applicable marketing preferences; and
·
for the establishment, exercise or defense of legal claims or whenever courts are
acting in their judicial capacity.
·
Legal Obligation:We
also process your personal data for compliance with a legal obligation to which
we are subject.
International Data Transfers
Personal data we collect may be transferred to, and
stored and processed in, the United States or any other country in which we or
our affiliates, partners or service providers maintain facilities or business
operations. We will ensure that transfers of personal data to a third country
or an international organization are subject to appropriate safeguards.
Your Privacy Rights
You have the following rights in respect of your personal
data:
·
Rights to Access, Correct and Delete:You have the right to
view, correct, update, or request the deletion of your personal data as set out
in detail in the Accessing and Deleting Your Information section above.
·
Right to Object:Where
we process your personal data based on legitimate interests, you may object to
the processing of your personal data based on grounds relating to your
particular situation. For example, you may control the extent to which we
market to you and you have the right to request that
we stop sending you marketing messages at any time. You can use the methods
described in the "Your Choices" section above.
·
Right to Withdraw Consent: Where
we process your personal data based on your consent, you have the right to
withdraw such consent to further use of your personal data at any time. You can
use the methods described in the "Your Choices" section above to
update your marketing preferences.
·
Right to Port Data: In
certain circumstances, you can request that we transfer or port personal data
that you have provided to us.
In certain circumstances, you can request that we
transfer or port personal data that you have provided to us.
We hope that we
can satisfy queries you may have about the way we process your personal data.
However, if you have unresolved concerns you also have
the right to complain to the relevant data protection authority. You can bring
the complaint in your member state of residence, place of work or where an
alleged infringement of data protection law occurred. For more information,
please contact your local data protection authority. Contact details for data
protection authorities in the European Economic Area and Switzerland are
available here.
Contact Information
If you have any questions about this Policy, please
contact us at:
New Leaf, Inc.
Attn: Privacy Policy
1278 Borregas Ave
Sunnyvale, CA 94089
Email: rasmussenlayton1995@gmail.com