PRIVACY POLICY

PLEASE NOTE THAT THIS PRIVACY POLICY APPLIES ONLY TO THOSE USERS OF THE SERVICES WHO ARE AGE 13 AND OLDER. SPECIAL PROCEDURES ARE USED WHEN COLLECTING INFORMATION FROM USERS UNDER THE AGE OF 13, WHICH ARE DISCUSSED IN THE "HOW WE PROTECT CHILDREN UNDER THE AGE OF 13" SECTION BELOW.

OVERVIEW

We, Sanrio Digital (HK) Limited, respect you, our user, and your privacy. It is our policy to comply with internationally recognized standards of personal data privacy protection. This statement set outs our privacy policies and practices in relation to the following:
  1. What information is collected
  2. How information is used
  3. Use of information in direct marketing
  4. With whom the information is shared
  5. How we protect children under the age of 13
  6. How you access or change your information
  7. Your options
  8. General

WHAT INFORMATION IS COLLECTED

We collect the following information from you. The first kind is personally identifiable information ("Personally Identifiable Information") which we collect during your registration for any of our services such as E-mail, message board etc ("Services"). Personally Identifiable Information may include your first and last name and year of birth. The second kind is non-personally identifiable information which includes your IP address (such as your computer's unique signature), your device's or platform's unique signature (such as your device's IMEI), operating system, browser software, Internet Service Provider, domain type and other numeric codes which identify a device or computer ("Aggregated Information").

HOW INFORMATION IS USED

Personally Identifiable Information is used solely for the purpose of identifying, managing and servicing individual user. If you consent or do not object to our use of your Personally Identifiable Information in direct marketing (please see further details in the "Use of Personally Identifiable Information in Direct Marketing" section below), we may use such information to conduct direct marketing activities, such as sending you offers, promotions, rewards, discounts, events and benefits in relation to the Services and products and services offered by our business partners or third party merchants. Aggregated Information is collected to help us to compile aggregate statistics on the usage of our applications and/or website and to analyse our users' demographics, interests and behaviour. This will give us a better understanding of the needs of our users and design our services and products accordingly.

USE OF INFORMATION IN DIRECT MARKETING

From time to time, we may conduct direct marketing of the Services through email, direct mails, telemarketing, fax and/or other form of communication to you. We intend to use your Personally Identifiable Information for direct marketing carried out by us or one of our business partners or third party merchants. For the purpose of direct marketing, we shall use your name (including surname and given name), address, telephone number, email address and other information, if any, that you provide to us for offers, promotions, rewards, discounts, events and benefits in relation to the Services and products and services offered by our business partners or third party merchants. Please note that we may not use or provide your Personally Identifiable Information to others for direct marketing purposes unless exempted by the relevant regulations or we have received your consent (which includes an indication of no objection). You may indicate your consent to the above by ticking the box(es) indicating your consent contained in the relevant communications. If you do not wish (i) any of your Personally Identifiable Information to be used in any of the described direct marketing activities, or (ii) to receive from us (a) any promotional and direct marketing materials, (b) any particular types of promotional and direct marketing materials, and/or (c) such materials through any particular means of communication, you can at any time opt-out, free-of-charge, by contacting us at gamesupport@sanriodigital.com, following the "opt-out" instructions contained in the relevant communications, or following the instructions in the "Your Options" section below.

WITH WHOM THE INFORMATION IS SHARED

We do not disclose any of your Personally Identifiable Information to any third parties except: We only share your Personally Identifiable Information with our business partners in accordance with our operating agreements with them. We only share the Aggregate Information about our users with our advertising partners. We need to do this so that our advertising partners can target their advertisements at the right audiences. Please however note that we do not give your Personally Identifiable Information to any of our advertising partners. You may request us to send to you further details of any advertisements in our applications and/or on our websites. We will ask our relevant advertising partners for those details and forward them to you by e-mail. For such request, please contact gamesupport@sanriodigital.com. Please be aware that when you click on the advertising banners in our applications, on our websites or in any marketing emails, you may be linked to websites which are not operated by us. We are not responsible for the collection or use of any information which you provide to those websites. We strongly recommend that you should review the privacy policy statements of those websites which collect information from you.

HOW WE PROTECT CHILDREN UNDER THE AGE OF 13

Please note that this "How We Protect Children Under the Age of 13" section only applies to procedures when collecting information from children under the age of 13. We do not knowingly collect Personally Identifiable Information from persons under the age of 13. If we collect any Personally Identifiable Information (or "Personal Information" as defined in the Children's Online Privacy Protection Act ("COPPA"), which was established by U.S. Congress to protect children's online privacy) from children under the age of 13, we will either (1) comply with the requirements of COPPA and gain prior verifiable parental consent or direct parental notification of the nature and intended use of such information, which shall include an opportunity for the parent to prevent use of the information and participation in the activity; or (2) take all reasonable steps to promptly remove from our files and records such information. For more information about COPPA and children's rights to online privacy, please visit the Children's Privacy section of the Federal Trade Commission's website at http://www.business.ftc.gov/privacy-and-security/childrens-privacy. If you believe that a child under 13 has gained access to our applications and/or website, or if you have any questions concerning our privacy policy and practices, please contact us at gamesupport@sanriodigital.com.

A. What types of information do we collect from children?

We mainly collect persistent identifier (such as an IP address, mobile device id, or a unique device identifier) from the child. We may also collect the email address of the child. Please note that all sites that are directed to children under the age of 13 are prohibited by COPPA from conditioning a child's participation in an online activity on the child's disclosure of more Personally Identifiable Information than is reasonably necessary to participate in the activity.

B. How do we use and share the Personally Identifiable Information collected from children?

We use the collected persistent identifier for the sole purpose of providing support for internal operations of the Service, including activities necessary for us to maintain or analyze the functioning of the Services, authenticate users or personalize content, serve contextual advertising or cap the frequency of advertising, protect the security or integrity of the user or the Service, or ensure legal or regulatory compliance. The collected persistent identifier is not shared with other third parties. However, we may, from time to time contract with certain third party service providers to provide support for the internal operations of the Service. Your Personally Identifiable Information is not used or disclosed by these contracted third party service providers except for the limited service for which they have been contracted. We collect a child's email address in connection with a question emailed to us by the child for the sole purpose of communicating with the child on a one-time-only basis (e.g. responding to a question from the child). We will not use or disclose such information to re-contact the child or for any other purpose, and such information will be deleted from our records promptly after responding to the child's request. If we choose not to respond to the child's request, we will immediately delete the child's information.

C. How can parents review or delete Personally Identifiable Information about their child?

At any time, parents of children under the age of 13 may review or delete Personally Identifiable Information about their children from our records, or refuse to permit our further collection or use of such Personally Identifiable Information. Please contact us at gamesupport@sanriodigital.com if you would like to review or delete your child's Personally Identifiable Information, or to inform us about your refusal to permit our further collection of such Personally Identifiable Information. Whenever a parent requests a deletion of his or her child's Personally Identifiable Information, we will use reasonable efforts to delete the child's information from our records as much as possible and will not collect any other Personally Identifiable Information from such child. Please note that there may be residual information that will remain in our records that may or may not contain the Personally Identifiable Information that was requested to be deleted. Such residual information will not be disclosed or shared with any other third party or used for any commercial purpose.

D. Changes in our Privacy Policy Regarding Children Under the Age of 13?

We may amend our Privacy Policy regarding Children Under the Age of 13 at any time. We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share a child's Personally Identifiable Information. Please note that, at all times, parents should update their Personally Identifiable Information to provide us current e-mail addresses. We will apply material changes in our Privacy Policy regarding Children Under the Age of 13 only in conformance with applicable law, including any applicable provisions of COPPA that require parental consent.

E. Contact us

If you have any other questions about our Privacy Policy for Children Under the Age of 13, including our practices in relation to children's Personally Identifiable Information, in particular collecting or maintaining such Personally Identifiable Information, please contact us at: Sanrio Digital (HK) Limited Unit 1109, Cyberport 2, 100 Cyberport Road, Hong Kong. Attention: Legal Department or send us an email at: gamesupport@sanriodigital.com Or call us at: (852) 9101 3960

HOW YOU ACCESS OR CHANGE YOUR INFORMATION

You have the right to access and change any of your Personally Identifiable Information collected by us. If you would like to access or change your information, please follow the simple instruction in your user account option or please contact us at gamesupport@sanriodigital.com.

YOUR OPTIONS

You may not wish to disclose any of your information, even though such information may be necessary to take advantage of or register for certain features of the Services. Please let us know at gamesupport@sanriodigital.com if you decide to opt out from receiving direct marketing materials from us or not to receive email or other mail from us in the future. If you do not wish to receive any legal notices from us, including this Privacy Policy, such legal notices will continue to govern your use of the Services, and you are responsible for reviewing such legal notices for any changes.

GENERAL

We reserve the right to amend this Privacy Policy Statement at any time without prior notice and only the current Privacy Policy Statement may be deemed effective. By registering for any of our services, you also consent to the transfer of any of your information collected by us to other jurisdictions which may not have any laws protecting Personally Identifiable Information similar to those in your jurisdiction. If you have any questions concerning our use of your Personally Identifiable Information, please contact us at gamesupport@sanriodigital.com. Last updated June 2013
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