1. What information do we collect from you?
We may collect and process the following data about you:
Personally Identifiable Information: This refers to information that let us know the specifics of who you are. When you engage in certain activities while using our Services, such as registering a user account, downloading and installing Application(s), playing Game(s), purchasing Virtual Money or Virtual Goods, sending and/or posting a user Content, entering a sweepstakes or contest, registering or participating in an event or promotion, or sending us feedback, we may ask you to provide certain information about yourself. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information. Such information may include but not limited to your first and last name, username, mailing address, e-mail address, telephone number, credit card or other payment information.
Usage Information: We collect details of your use of our Services and the resources that you access. Such usage information may include information about how and when you access or use our Services (such as Games accessed, game score, pages visited, purchase and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your game play).
Interaction and Communications among Users: We collect information about (i) your interaction with other users (for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and (ii) your communication and interaction with your contacts through social media channels (including, social network services, messengers, chats and any other services which has social features like invite friends and sharing information with friends).
Technical Information: We collect general technical data pertaining to you (such as information about the device you use to access our Services, IP address, telephone number assigned and associated with your device, operating system, browser type, device identifier, advertising ID, locale, and other system information).
User Communication with snowpipe: If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence.
Such Public Posting or shared content will be visible to anyone who has access to our Services and may also be viewable outside of our Websites or Services. You should exercise caution in all public postings, as it may result in the disclosure of private information, for which we are not responsible.
Information We Collect from Third Parties: We receive information about you from third parties (i) when you purchase our games or download Application from another party, such as Google Play, Apple App store or (ii) when you choose to sign in to our Website or Application using a third-party social network account (such as Facebook or Game Center). The information we receive from such third parties may include your name, user name, photographs, and other biographic information, and device identifier, network service account number assigned by such third party, and Game usage data. You should review the Terms of Service and privacy policies of such third parties and understand how they treat your data and what data they might share with us.
Payment: When you purchase our products or services through third party platforms (such as Apple App Store, Google Play Store), you will be required to provide certain payment and billing information directly to such third party platforms, and we do not collect or store any payment information from you.
Friends Matching: With your consent, we may periodically access your contacts and friends list on your mobile device and/or your social network account(s) that you use to sign in to our Website or Application. We will use your contacts’ information to help you find your friends and play our Games socially with them.
Customer Support Correspondence: When you contact our customer support team for assistance, we may ask for your name and contact information and any other information needed or relevant to assist you with your inquiry, including without limitation any transaction and payment information.
2. How do we use the information collected?
snowpipe may use the information we collect through your use of the snowpipe Service for providing enhanced game services and promotional information regarding snowpipe Games. For example, we may use the information we collect in any of the following ways:
• Creating your Game Account and managing the account information;
• Informing you of (a) products, new products, services, features, promotions, enhancements, and updates regarding the snowpipe Service and (b) updates to the snowpipe Policy;
• Promoting and facilitating your use of the snowpipe Service, including the targeted advertising and affiliate marketing;
• Marketing snowpipe Games to you, including sending you offers, promotion information, newsletters, local or push notifications, e-mail campaigns, and communications regarding new, improved or existing snowpipe Games;
• Providing customer support and responding to user inquiries;
• Fulfilling your request and/or order for snowpipe Games and our obligations under the snowpipe Policy;
• Enabling user-to-user communication and interaction;
• Soliciting your input and feedback to improve user experience;
• Monitoring the technical functioning of the snowpipe Service;
• Developing new and/or improved games, products, services or offerings;
• Analyzing market trends and user traffic;
• Trouble-shooting errors or issues with any of the snowpipe Service; and
• Complying with applicable laws, regulations, or administrative orders.
Also, snowpipe may combine your information in an attempt to provide you with a better user experience, to improve the quality and value of the snowpipe Service and to analyze how the snowpipe Service is used.
• Maintain your session when you use the Service.
• Enhance security.
• Remember information about your browser and your preferences.
• Understand how people use the Services in order to improve the Service.
4. With whom do we share your information?
Generally: We do provide some of our Services through contractual arrangement services providers, and other third parties (collectively, “Service Providers”).
We may also share your personal information when we determine that it is reasonably necessary (i) to comply with any legal obligation, (ii) to enforce or apply our terms and conditions and/or any other agreement with you; or (iii) to protect the rights, property, or safety of us, our users, or others; or (iv) for other purposes as we reasonably believe are permitted by law or regulation.
Sharing of Non-Personally Identifiable Information: We may also provide non-personally identifiable information about users (where your data is on an anonymous and aggregated basis) to third party companies, including but not limited to third party advertisers, consultants, service providers. Such data will not include any information by which you could be personally identified.
Social Features: When you use the social features of our Services, we share information about you, including your name, user ID, social media profile, picture, game scores and progress, and any other information that you submit or post using such social features. For example, other players may see your name, picture, profile information, and your scores and game progress. In addition, information or message that you submit or post through message boards, forums and/or chat areas will be published on our Websites, Applications, and/or third-party social media network that you sign on.
Compliance with Legal Obligations: Occasionally we may be required by law to disclose personally identifiable information. For example, we disclose such information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
5. How do we keep your information secure?
We will use reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Even though we make good faith efforts to store and protect 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.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
6. Where do we hold your information?
Your personal information may be transferred to, and stored at, a destination outside of your country or jurisdiction, including but not limited to our data center in Korea. It may also be processed by personnel and third-party service provider who may operate outside of your country or jurisdiction. In such case, we will take reasonable steps to require such third party in possession of your personal information to take commercially reasonable security measures to protect the information. On the other hand, the data and privacy protection laws of other countries may not be as comprehensive as those laws in your country of residence. By using our Services, you consent to your personal information being transferred to recipients in other countries and being stored and processed in the servers located in other countries.
7. How can you review, correct or delete your personally identifiable information?
You can request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please submit your request in writing at Customer Center or by e-mailing us at email@example.com
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove your personal information by contacting us at firstname.lastname@example.org You may also update your account information by logging into your account.
You may request to delete your account by logging in to the account that you wish to delete and going to the Customer Support menu to submit your request. We may ask you for certain personal information to confirm your identity before processing your request. Please note that before we process your deletion request, we will ask you to verify your account information or log into the account you wish to delete to confirm your identity. In addition, if you have multiple Game profiles, you’ll need to make separate requests for each Game profile that you wish to close.
Please be aware that we may not be able to delete your information in some cases. For example, we cannot correct or delete any information that you have shared on any third-party social network or platform. Likewise, any information that you have publicly shared through our Services may be copied by a third party whom we do not control, and we may not be able to remove such information. In addition, any information that is saved in aggregate form or that cannot, in our sole discretion, be removed without undue burden to us may not be deleted.
Any third-party platform that you use to access the Services may also retain backup copies of your information even after your account is deleted or terminated and may use them subject to their policies.
8. YOUR CHOICES
snowpipe provides you with a variety of choices to control the use and sharing of your information, including:
Email Communications. You may opt out of receiving commercial email messages from us by following the unsubscribe instructions provided in our emails. Please note that even if you have opted out of receiving commercial email messages, you may continue to receive messages related to your account, your transactions, and similar service-related messages.
Geolocation Information. Your device may enable you to control the collection of your precise geolocation information, and whether this information is shared with third parties, through the settings on your device. Please note that you may need to adjust multiple settings, and not just your location permissions, to opt out of providing precise location information. If you opt out of providing precise geolocation information, we may continue to derive your approximate location from your IP address and other information we may collect. For more information, please review your device settings.
Cookies and Similar Technologies. You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable local storage and similar technologies. For example, Adobe Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page. Deleting the cookies in your browser may in some cases cancel your choices for interest-based advertising. If you choose to refuse, disable, or delete cookies and similar technologies, some of the functionality of the Services may no longer be available to you.
Do Not Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. snowpipe currently does not take action in response to these signals.
Interest-Based Advertising. While it is not possible to turn off all advertising, you do have the ability to control whether you receive interest-based ads based on information collected or received about your online activities and interests over time and across unaffiliated sites and services and your different devices. You can opt out of receiving interest-based ads from companies that participate in self-regulatory programs such as the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), EDAA (EU), and DAAC (Canada) by following the instructions provided on their websites. If you are using a mobile app, you also may need to opt out of interest-based advertising on your mobile device or through the mobile application. For more information, check your device and mobile app settings. Please note that your opt-out choice will apply only to the browser and device you are using when you opt out.
Other Game and Device Permissions. You may be able to adjust your privacy settings for push notifications, address book sharing, and other information or features within the Services or your device permissions. Please review the settings for the Services and your device for more information. To stop the collection of information by a snowpipe game, you can uninstall the game using the standard uninstall process available on your device or the app marketplace or network from which you installed the game.
Data Rights and Withdrawal of Consent
The laws in your country may provide you rights to request access to, correct, restrict, port, copy, or delete your information, request that we stop processing your information or delete your account, or withdraw or change the scope of your consent. If you withdraw your consent, we will stop processing your information for such purposes, but it will not affect the processing of information previously covered by your consent. Where technologically feasible and required by applicable law, we will port your information pursuant to your reasonable request. A request to withdraw consent, restrict or stop processing your information, or delete your account or information may result in your inability to access the Services or some of its features. To exercise your rights consistent with applicable law, please contact us.
9. What should you know about privacy policies and data collection at any third party sites accessible from our Services?
10. How long do we retain your personal information?
11. Our Policy Concerning Children
As used herein, the “child” or “children” means under the age of 13, and the term “parent” includes legal guardians.
Our Games and related Services are intended for general audience. We do not knowingly collect, use or share any personally identifiable information about children without verifiable parental consent or as permitted by law. If you are a parent and you believe your child has provided us with personal information, you can contact us and request your child’s information to be deleted from our system.
Once a user indicates that he or she is under the age of 13, we will not collect any personal information from that user except certain limited information permitted by the law. For example, we may ask for the name and online contact information of a child user’s parent in order to provide notice and obtain a parental consent. In addition, we may collect certain information permitted by the law to support and protect the security, integrity and operation of our Services.
If a child states that his/her age is under 13, we will seek consent from the child’s parent before collecting personal information from the child; except we may collect and use certain information from the child for limited purposes without obtaining parental consent where permitted to do so by law.
We generally do not offer children who identify themselves as being under 13 the chat functionality or services that enable them to publicly disclose personal information (such as online forum, messenger, or e-mail)(collectively, “Communication Services”). However, if we offer such Communication Services as part of our Game or Services to children, we will restrict the child from accessing them until we receive a verifiable consent from the child’s parent.
Parents can review the personal information we have collected from their child and request them to be deleted. Parents can also revoke their previously provided consent to collection or use of the child’s information. If you are a parent and wish to review, modify, or delete your child’s personal information, or withdraw consent, you can submit a request to our Privacy Administrator at the address, e-mail address or telephone number provided below.
snowpipe co., Ltd
Attn: Privacy Administrator
[Address] 9F Kuk Dong Tower Apgujeong-ro 152 Gangnam-gu, Seoul
12. Changes to the Policy
13. EU Data Protection Rights
Only the minimum required personal information of users in the EU domain will be collected in order to execute the Games and provide the Services, and any other information will be collected only with the consent of the user. You have the right to object to the way your personal information is processed by snowpipe by contacting snowpipe’s Customer Center. Residents of EU Member States may contact snowpipe’s Customer Center for any unreasonable treatment that exceeds the time or other limits required by law. You may also be able to request judicial relief from the authorities in certain situations.
14. Governing Law
The Terms of Service are governed by and construed in accordance with the laws of the Republic of Korea without regard to its conflict of law provisions. You and snowpipe hereby agree that any and all claims, causes of action or disputes (regardless of theory) arising out of or relating to the Terms of the Service or the relationship between you and snowpipe, shall be brought exclusively to the Seoul Central District Court in the Republic of Korea.
15. Our Contact Information