SECTION 1 - WHAT DOES AITHER DO WITH USER’S INFORMATION?
Aither may collect the following information and data from user:
- Contact information (such as name and email address);
- For posting on our forum(s) (if applicable), user’s Username and password;
- Profile information that user volunteers (such as profile photo, gender, age or birthday, links to profiles on other social networking websites) to be posted on the Sites;
- When user browses the Sites, such Sites also automatically receive user’s internet protocol (“IP”) address, type of user’s device’s operating system (“OS”), browser type and language;
- Employment information (resume, name, email address, phone number);
- For e-mail marketing (if applicable) purposes and with user’s permission, Aither may send user emails about its store’s information, new products and other updates;
- For E-commerce (if applicable:) purposes, when user purchases something from Aither’s stores, as part of the buying and selling process, Aither will collect the user’s personal information, such as user’s name, address and email address.
- For usage of Aither’s Game/Application (aka App) (if applicable) when user downloads and uses such Game/ Application, Aither will not collect any information that constitutes users “personally identifiable information”. Aither may however collect certain non-personally identifying information and /or data about user (“Non-Identifying Information”). The type of Non-Identifying Information Aither collects includes, but is not limited to: (i) mobile device type, device identification code, device properties, mobile device identifiers (such as user’s unique device ID (persistent/non-persistent, hardware type, medial access control ("MAC") address, international mobile equipment identity ("IMEI"), and user’s device name (ii) geographical data; (iii) Aither’s Game data such as user’s interactions with such game and with the other players inside such game via server log files, user’s player ID, scores and achievements within the Application; and (iv) ads user click on within the Application;
- For Tracking Technologies (if applicable) purposes, Aither may also permit Aither’s Advertising Display Partners to collect Non-Identifying Information about users while users are using the Application. Please visit Aither’s Advertising Display Partners’ websites to find their own privacy policies regarding their use of users’ Non-Identifying Information. Please note that some of Aither’s Advertising Display Partners may send targeted advertisements based on user behavior;
- For purposes required by Aither and Aither’s marketing and outsourcing partners, affiliates, or analytics service providers to improve on the quality of the Services (such as tailoring recommendations to user’s interests and making the Services easier to use), they may each use technologies such as cookies, beacons, scripts, and tags to identify a user's computer/device and such information contained in a cookie may be linked to user’s personal information . Users can disable cookies at any time, although users may consequently not be able to access or use certain or all of the features of the Services.
- For Sweepstakes or Contest (if applicable) purposes, Aither may provide users the opportunity to participate in a sweepstakes or contest through Aither’s Service. If user participates, Aither will request certain personal information from user. Participation in these sweepstakes and contests are voluntary and user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and email address), and demographic information (such as zip code or geographical location). Aither uses this information to notify winners and award prizes, to monitor traffic or personalize the Service. Aither may use a third party service provider to conduct these sweepstakes or contests; such company is prohibited from using users' personal information for any other purpose.
SECTION 2 - CONSENT
How does Aither get user’s consent?
By using the Service, users are explicitly agreeing to the terms of this Policy and the processing of user’s information and data, including user’s personal information, in the manner provided in this Policy. If user does not agree to these Policy’s terms, please do not use the Service.
When user provides Aither with personal information to complete a transaction, verify user’s credit card, place an order, arrange for a delivery or return a purchase, Aither has implicitly obtaine user’s consent for Aither’s collection of such information and to be using the same for that specific reason only.
If Aither asks for user’s personal information for a secondary reason, like marketing purposes, Aither will either ask user directly for user’s explicit consent, or provide user with an opportunity to say no.
How does user withdraw a given consent?
Upon request, Aither will provide user with information about whether Aither holds any of user’s personal information. If user’s personal information changes, or if user no longer wants to use Aither’s Services, user may correct, update, delete inaccuracies, or delete user’s personal information by making the changes within user’s account settings or by contacting Aither for it to do so for user. In some cases, Aither may not be able to remove user’s personal information, in which case Aither will let user know if Aither has been unable to do so and why. Aither will respond to user’s access request within a reasonable timeframe.
“Opting Out of Marketing:: User may opt-out of receiving promotional emails from Aither by following the instructions in such promotional emails or by emailing Aither with the contact information provided in this Policy. If user opts-out, Aither may still send user non-promotional emails, such as emails about user’s accounts or Aither’s ongoing business relations. User may also opt-out of receiving SMS notifications from Aither, either via SMS or by emailing Aither.
If user has an unresolved privacy or data use concern that Aither has not addressed satisfactorily for the continued collection, use or disclosure of user’s information, user may at anytime, alert Aither by contacting Aither either by emailing: [email protected]; or by post to: Aither Entertainment Limited 13/F, Zung Fu Industial Building, 1067 King's Road, Quarry Bay, Hong Kong.
SECTION 3 - HOW AITHER USES USER’S INFORMATION
Aither 's necessity in using information from users is to create user’s account, provide Services to user, let user administer the use of Aither’s Game/ Aapplication, improve Aither’s Services, contact user, conduct marketing and research and create reports for Aither’s internal use. Aither stores information on servers located in the United States via Amazon Web Services and may choose to also store information on servers and equipment in other countries.
Aither uses information collected through Aither’s Services for purposes described in this Policy or disclosed to user in connection with Aither’s Services. For example, Aither may use user’s information to:
- Create game accounts and allow users to play Aither’s games;
- Identify and suggest connections with other Aither’s users;
- Operate and improve Aither’s Services;
- Understand users and each user’s preferences to enhance user’s experience and enjoyment using Aither’s Services;
- Respond to User’s comments and questions and provide customer service;
- Provide and deliver products and services user request;
- Deliver advertising and marketing and promotional information to user;
- Send user related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- Communicate with user about promotions, rewards, upcoming events, and other news about products and services offered by Aither and Aither’s selected partners;
- Enable each user to communicate with other users; and
- Link or combine it with other information Aither get from third parties, to help understand user’s preferences and provide user with better services.
Aither will also be collecting and using user’s information for the performance of the Services, including the following services and activities:
- Website Services
- While user is browsing the Sites, user’s computer's OS, IP address, access times, browser type and language and referring Web site addresses may be logged automatically. Aither may use this information to monitor, develop and analyze user’s use of the Service.
- Aither may ask user to submit, and Aither may process, data that is personal to user, including but not limited to user’s name, profile photo, gender, age or birthday, links to user’s profiles on social networking websites and other third party sites, user names and e-mail and mailing addresses. Aither may use this information to create a user profile and provide user Services.
- Customer Services
- When user contacts Aither’s customer service group, Aither may use user’s email address to ask user about user’s gaming experience with Aither’s Games and to notify user about company news and promotions.
- If user no longer wishes to receive certain email notifications from Aither, user may opt-out at any time by following the “unsubscribe link” located at the bottom of each email communication or by emailing Aither with the contact information provided in this Policy.
- User’s mailing address may be used if Aither has merchandise or other physical promotional materials that Aither want to mail by post to user. If user no longer wishes to receive these types of promotional materials, user may opt-out from receiving them at any time by emailing Aither with the contact information provided in this Policy.
- Third Party Services
- Applications for Employment
- If user wishes to submit a resume, Aither provides user the option to upload it to the relevant Site(s) and Aither will thereunder collect user’s name, email address and mobile telephone number. Aither uses this information to contact user regarding setting up an interview or to determine if user is qualified for the position in which user has applied.
- Mobile Applications
- When user uses any of the Aither’s Games or Applications on a mobile platform, Aither may record certain information and data, such as user’s application usage, access, session times and in-app purchases, user’s unique device ID (persistent / non-persistent), hardware type, MAC address, IMEI, the version of user’s OS, user’s device name, user’s email address (if user has connected to a Social Network), and user’s location (based on user’s IP address). This information is useful to Aither for troubleshooting and helps Aither understand usage trends and improve and optimize the Services and user experience, and may also be utilized for other purposes, such as interest based advertising as described elsewhere in this Policy.
- In addition, Aither creates a unique user ID to track user use of Aither’s Service. This unique user ID is stored in connection with user’s profile information to track the Aither’s Games which users are playing.
- Aither may occasionally send users push notifications through Aither’s mobile applications to send each user’s Game updates, high scores and other service related notifications that may be of importance to such user. User may at any time opt-out from receiving these types of communications by turning them off at the device level through user’s settings.
- With only user’s express consent, Aither or Aither’s partners may collect user’s precise location based information (GPS) for the purpose of matching user with opponent players in user’s local area, to tailor content specific to user’s area (such as event announcements), to show user’s location to other players, and to match user’s device location to certain points of interest for purposes of interest based advertising as described elsewhere in this Policy. Other players in Aither’s Game may then be able to see that user are available to play a game when user participate in specific areas of Aither’s Games. Please note that participation in this part of the Services is not a requirement for all gameplay in Aither’s Games, but it may be a requirement for example to participate in local gameplay with others in users in the relevant geographical area.
- Advertising Activities
- Advertisers on mobile devices and Aither’s third party advertising and analytics partners sometimes collect and use Advertising IDs to enable and optimize advertising. Advertising IDs are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising.
- These advertisers and third party advertising and analytics partners may collect and use data and information about users, such as user’s Service session activity, viewing of and interaction with an advertisement, device identifier, MAC address, IMEI, geo-location information and IP address for the purposes of analyzing, tracking and measuring advertisement performance and to provide interest based advertising.
- In addition, user may see Aither’s games advertised in other services. After clicking on one of these advertisements and installing Aither’s game, user will become a user of Aither’s Service. In order to verify the installs, a device identifier may be shared with the advertiser or third party advertiser or analytics partner.
SECTION 4 - DISCLOSURE
Aither does not share user’s personal information except as approved by user or as described below:
- Compliance with Laws and Law Enforcement: Aither cooperates with government and law enforcement officials and private parties to enforce and comply with the relevant applicable laws. Aither will disclose any information Aither possesses about users to government or law enforcement officials or private parties as Aither, in Aither’s sole discretion, believes necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect the property and rights of Aither or a third party, to protect the safety of the public or any person, or to prevent or stop any activity Aither may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. This includes exchanging information with other companies and organizations for fraud protection. In certain situations, Aither may be required to disclose personal information in response to lawful requests by public authorities or for local law enforcement requirements
- Business Transfers: Aither may sell, transfer or otherwise share some or all of its assets, including user’s Non-Identifying Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. User will be notified via email and/or notice on Aither’s Sites of any change in ownership or users of personal information.
- Aither may share aggregate, santized or anonymized information about users with the following advertisers, publishers, business partners, sponsors, and other third parties.
- Advertising Display Partners. Aither will share user’s Non-Identifying Information with advertising service provider companies with whom Aither have relationships, including but not limited to Admob, Tapjoy and Greystripe, Mopub, Inmobi, Mobfox, Tapit (collectively, “Advertising Display Partners”). Please visit Aither’s Advertising Display Partners’ websites to find their respective privacy policies regarding their respective use of user’s Non-Identifying Information. As noted above, some of Aither’s Advertising Display Partners may send targeted advertisements based on user behavior.
- Service Providers. Aither may engage third party companies and individuals to facilitate Aither’s Application, to provide the Application on Aither’s behalf, to perform Application-related services (including but not limited to maintenance services, database management, web analytics and improvement of the Application’s features) or to assist us in analyzing how Aither’s Application and service are used. These third parties have access to user’s information only for purposes of performing these tasks on Aither’s behalf.
SECTION 5 - SECURITY
Aither is very concerned with safeguarding user’s information. Aither employs reasonable measures designed to protect user’s information from unauthorized access or against loss, misuse or alteration by third parties.
Although Aither makes good faith efforts to store the information collected on the Services in a secure operating environment that is not available to the public, Aither cannot guarantee the absolute security of that information during its transmission or its storage on Aither’s systems. Further, while Aither attempts to ensure the integrity and security of network and systems, Aither cannot guarantee that Aither’s security measures will prevent third-party "hackers" from illegally obtaining access to this information. Aither does not warrant or represent that user’s information will be protected against, loss, misuse, or alteration by third parties. User acknowledges that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, Aither cannot guarantee absolute security of user’s information.
SECTION 6 - AGE OF CONSENT
Aither retain user’s information for as long as user’s account is active or as needed to provide user Services. Aither will also retain and use user’s information as necessary to comply with Aither’s internal archival policies, regulatory reporting purposes, legal obligations, resolve disputes, and enforce Aither’s agreements.
SECTION 7 - PERSONAL INFORMATION OF MINORS
Aither does not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use Aither’s Services. If user is under 13, please do not send any personal information to Aither, including user’s name, mailing address, telephone number, or email address. No one under the age of 13 may provide any personal information to Aither. In the event that Aither learns that Aither has inadvertently collected personal information from a child under age 13, Aither will delete that information as quickly as possible. If user believes that Aither might have any information from or about a child under the age of 13, please contact Aither.
QUESTIONS AND CONTACT INFORMATION
If users would like to: (i) access, correct, amend or delete any personal information Aither may have about users, (ii) register a complaint, or (iii) simply want more information, users may contact Aither’s Privacy Compliance Officer by emailing him/her at [email protected] or by post at Aither Entertainment Limited
[Re: Privacy Compliance Officer]
[13/F, Zung Fu Industial Building, 1067 King's Road, Quarry Bay, Hong Kong, 852, Hong Kong]