CYBERSTEP COMMUNICATIONS, INC.
Last Updated: February 12th, 2020
I. INFORMATION WE COLLECT
We may collect through the Service both personal information that identifies you and can be used to contact you, and non-personal information, which is data in a form that does not allow direct association with you, which may include technical information, such as the IP address through which you are accessing the Service and the unique mobile device ID or virtual unique device identifier for any mobile device you may be using.
A. Personal Information
For users in the EEA, the legal basis for collection of this information is to provide you with the Services.
Please note that some non-personal information would be considered a part of your personal information if it were combined with other information in a way that enables you to be identified, but the same information is considered non-personal information when taken alone or combined only with other non-personal information.
B. Non-Personal Information
Non-personal information, alone, cannot be used to identify or contact you. CyberStep collects non-personal information about your use of Service and includes aggregated information regarding usage of the Service. The non-personal information collected may include information related to your mobile device or computer system, including mobile device type, IP address, unique mobile device ID or other device identifiers, Media Access Control (MAC) address, telephone number of mobile device, country of registration (together, “Device Information”). It may also include browser type, language, Internet Service Provider (ISP), referring and exit pages, time spent, information searched for, time and date stamp, clickstream data, feature usage, game play statistics, scores and achievements, user rankings, time spent playing our games, and other statistics. CyberStep also collects login information, user ID and other information from any SNS that you may use to access the Service, or that you may interact with through the Service, as described in more detail under the subsection below “Interaction with SNS’s”.
II. HOW WE USE YOUR INFORMATION
Generally, we use your information to provide you with an efficient and customized experience. For example, we may use information in the following ways:
- To send to you any physical prizes that you have requested we deliver to you, and to communicate with you about sending the prizes.
- To send “push” notifications to your mobile device regarding the Service (for example, suggesting that you open the Service to take certain actions);
- To provide in-game information regarding player achievements, such as leader boards;
- To allow us to enable you to reset your password if you have forgotten it;
- To provide technical support and respond to inquiries from you;
- To prevent fraud and potentially illegal activities and enforce our Terms of Service; and
- To help us to develop, deliver and improve the Service.
For users in the EEA, the legal basis for processing of the above personal information is to provide you with the Service you have requested.
Additionally, we may use your information to promote the Service and additional products or services, including:
- To inform you about new CyberStep products and services and promote products and services of CyberStep and other companies in our corporate group;
- For market research purposes that support our efforts to deliver a more valuable service to our community of CyberStep users;
- To deliver and target advertising from third parties;
- To gather demographic information about CyberStep users in order to more effectively manage the Service and provide targeted advertising; and
- To track clicks or other ad fulfillment metrics.
The EEA legal basis for this processing of your personal information is our pursuit of legitimate interests, specifically in this case the legitimate interest to optimize your experience with the Services by avoiding display of recommendations and offers that are irrelevant to you. If you or the relevant Data Controller are located in the EEA, you have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right, you may do so by contacting us as provided in the “Contact” link below.
Telephone numbers will be used solely to send SMS messages or to contact you regarding shipment of any prizes you may have asked us to ship. If we send e-mail or SMS messages to you for the purpose of promoting CyberStep products or services, or those of a third-party partner, we will generally provide you with choices about receiving further such promotional messages. Preferences for “push” notifications may in most cases be adjusted through Service or your mobile device.
III. HOW WE COLLECT YOURINFORMATION AND HOW LONG WE KEEP IT
A. Interaction with SNS’s
By registering with your SNS login information, you allow CyberStep to access certain information from your profile for that SNS. The information you allow CyberStep to access is affected by the privacy settings you and your friends establish at the SNS. You can control and find out more about these settings directly from the SNS. For example, CyberStep may access and store some or all of the following information, as allowed by you, the SNS and your preferences:
- Your full name as provided to the SNS;
- Your date of birth;
- Your gender;
- Your physical location;
- Your SNS ID;
- The URL of your SNS profile;
- Your profile picture or its URL;
- Your user ID number, which is linked to publicly available information such as name and profile photo;
- The user ID numbers and other public data for your friends that are also connected to Service; and
- The login e-mail you provided to that SNS when you registered.
In addition, if you are a member of an SNS, the Service may also enable you to log in through an interface provided by that SNS. The Service may also enable you to access the SNS through the Service itself. If you log in to the Service using an SNS, or access an SNS through the Service, we may receive the personal and non-personal information that you have provided (or provide in the future) to that SNS.
You may be able to specify what information is provided by the SNS to CyberStep using the privacy settings in your SNS profile information.
B. Registration for the Service
To register for the Service, we may request that you provide your date of birth, e-mail address and telephone number.
You will also be required to create a user name for use in Service. That user name may be visible to other players. If you do not wish for other players to know your real name, do not include your real name in your user name.
C. Prize Fulfillment
If you win a physical prize through the Service and complete the form requesting it to be shipped to you, we will receive your physical mailing address, telephone number (if not previously provided) and other information you provide us.
If you request support relating to the Service, we may request personal information such as your name and e-mail address and your user name for any SNS’s, if that appears necessary to resolving the problem.
Our websites may require you to enter a region and language in order to provide relevant information in your language. In addition, your IP address or Device Information may allow us to determine your approximate geographic location (however, CyberStep does not access or use exact location information that may be transmitted by your mobile device).
E. Cookies and Other Technologies
A cookie is a small string of text that we, or service providers acting on our behalf, such as Google Analytics or other analytics services, send to your computer’s or mobile device’s browser. Other types of cookies exist, but the cookies in the Service are only used to obtain browser or device-specific information.
Some cookies are necessary to enable a game to function properly and to allow your gameplay experience to continue from one session another, or to prevent you from having to reenter your region and language each time you access our websites. Other cookies can show, for instance, which parts of Service are the most popular, how much time users are spending there, and how they are interacting with the content. Cookies may be linked to your CyberStep user ID. Cookies planted by CyberStep do not collect information from your computer or mobile device that is not related to the Service.
You may have the option to disable cookies by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the pages you visit. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer. If you do not accept cookies, however, you may not be able to use all portions of our Service.
We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “Pixel Tags”) in connection with the Service and to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s device or hard drive. Pixel Tags allow us to count users who have visited certain pages of the Service and to help determine the effectiveness of promotional or advertising campaigns.
F. Retention of Your Information
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or, where applicable law provides for longer storage and retention periods, for the storage and retention period required by law. After that your personal information will be deleted.
IV. HOW WE SHARE YOUR INFORMATION
A. Within Our Corporate Group
B. With Third-Party Advertising Companies
We will not share your personal information with third-party advertisers, advertising networks and advertising platforms (“Advertising Companies”) for their direct marketing purposes unless you provide your consent.
We may share certain non-personal information with Advertising Companies to develop and deliver targeted advertising in the Service and on the websites of third parties. We may also allow Advertising Companies to collect non-personal information within the Service which they may share with us, including your device location and Device Information. Advertising Companies may also collect non-personal information related to the performance of the advertisements, such as how many times an advertisement is shown, how long an advertisement is viewed, and any click-throughs of an advertisement. Advertising Companies may collect this information through the use of tracking technologies like browser cookies and web beacons.
Although CyberStep does not provide personal information to Advertising Companies, please note that Advertising Companies may combine non-personal information they receive from us with personally-identifiable information that they may have already received or may in the future receive from other sources.
C. With Other Service Providers
We use third-party payment gateways for processing payments made by you in the Service. The payment gateways will receive your credit card information, physical address and other information to verify your identity and process your payment. In addition, to help administer the Service, we may use third-party service providers, such as game developers and data analytics services. These payment gateways and service providers will have access to your information only to perform the services they have been engaged to perform for us, and they have agreed not to use it for any other purpose. They have also agreed not to disclose such information to third parties except under limited circumstances.
As with Advertising Companies, please note that data analytics providers may combine non-personal information they receive from us with personally-identifiable information that they may have already received or may in the future receive from other sources.
D. Under Special Circumstances
We may disclose information about you to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of CyberStep or a third party, to protect the safety of any person or to prevent or stop activity we may consider to be illegal or unethical.
In connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy, we may sell, transfer or otherwise share some or all of CyberStep assets, including your personal information.
We may share your personal information in connection with any Promotion you may enter, as necessary to administer, market, sponsor or provide fulfillment under the Promotion or as required by applicable law. This may include providing winner lists to other parties.
V. CHILDREN’S PRIVACY
The Service is not intended for children under the age of 13. We do not knowingly collect any personal information from children under the age of 13. Certain of our applications are not intended for persons under the age of 18, as specified in posted descriptions of those applications.
If we learn that we have inadvertently obtained personal information from a child under the age of 13, we will take reasonable measures to erase the information from our records. Parents or guardians who believe that CyberStep might have received any information from or about a child under 13 may submit a request to us at firstname.lastname@example.org and request that the information be removed.
We encourage you to talk with your children about communicating with strangers and disclosing personal information online.
VI. HOW WE PROTECT YOUR INFORMATION
CyberStep is committed to protecting the security of your information. We have implemented security measures to protect against identity theft and unauthorized access.
We do not and will not, at any time, request your credit card information, your login information or other identification in a non-secure or unsolicited communication (such as e-mail).
Should any breach of security occur, we will make any legally required disclosure to you by e-mail or posting on the Service as soon as reasonably possible, subject to (i) the requests of law enforcement and (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
VII. HOW YOU MAY CHANGE, REMOVE, OR EXPORT YOUR INFORMATION
You may email us at email@example.com to request that we delete your personal information from our database. In that case, please place “delete my account” in the subject line and include your first and last name and e-mail address in the body of the message. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for business administrative purposes.
Please note that communications you may send through the Service, as well as any comments you may post (and any content from those comments that have been incorporated in other users’ postings or submissions), will be stored by CyberStep, and will not be deleted unless we determine to do so in our sole discretion. Also, CyberStep is unable to delete content that you may have posted on an SNS or that may have been reposted by others on an SNS.
You may also control the information that CyberStep collects through the settings in your browser or mobile device. You may configure your browser to reject cookies from CyberStep and may adjust the settings of your mobile device to prevent the Service from obtaining location information. However, please note that the Service may rely on cookies and location information to function properly and some services may not be available if you disable cookies.
VIII. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
X. NON-US USERS
XI. RIGHTS OF USERS FROM THE EEA
A. Data Controller
B. Rights of EEA Residents
If you are accessing or using the website or application from within the EEA, you may have the following rights under the GDPR (as well as other rights). If you wish to exercise any of these rights, you may do so by contacting us as provided in the “Contact” link below, or as provided in the applicable section below.
- Right of Access: You have the right to obtain confirmation from us as to whether or not CyberStep processes personal information from you and you also have the right to at any time obtain access to your personal information stored by CyberStep.
- Right to Correction of your Personal Information: If we process your personal information, we use reasonable measures to ensure that your personal information is accurate and up-to-date for the purposes for which your personal information was collected. If your personal information is inaccurate or incomplete, you have the right to require us to correct it.
- Right to Deletion of your Personal Information or Right to Restriction of Processing: You may have the right to require us to delete your personal information or to restrict of processing of your personal information.
- Right to Withdraw your Consent: If you have given your consent to the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal.
- Right to Data Portability: You may have the right to receive the personal information concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.
- Right to Lodge a Complaint with Supervisory Authority: You have the right to lodge a complaint with a data protection supervisory authority located in the European Union. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
XII. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a resident of California, USA resident and CyberStep user, you are entitled to request certain information regarding our disclosure of certain “personal information” (as defined in California Civil Code Section 1798.83) to third parties for their direct marketing purposes. If you are a California resident and have provided CyberStep with personal information within the last year, you may make such a request by emailing us at firstname.lastname@example.org and typing the following in the subject line of the e-mail: “California Privacy Rights”.
Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the e-mail address above.
XIII. DO NOT TRACK DISCLOSURE
CyberStep does not respond to “Do Not Track” browser signals or other mechanisms. Third parties may collect personal information about your online activities over time and across sites when you use the Service.
XIV. DISPUTES; BINDING ARBITRATION
XV. CONTACTING CYBERSTEP