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Skullwink Entertainment Privacy Policy

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Larry Ted McBride (‘the Developer’, ‘Skullwink’) and Skullwink Entertainment ('we' or 'us') respects the privacy of its players ('you' or 'your') and recognize the importance of providing a secure environment for them. We have adopted this Privacy Policy (“Privacy Policy”) to explain how we collect, store, and use the information you provide us. This Privacy Policy details how the Developer safeguards the privacy of its players. Please note that when you click a link to other sites from a Skullwink game, this Privacy Policy does not apply to, and cannot control the activities on, those other sites. We highly recommend that you read the privacy policy of any third party website you may be directed to before providing any personally identifiable information.

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Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Platform and any related the Developer’s webpages, mobile sites or mobile applications. If you do not agree with our Terms of Use and/or the Privacy Policy, please refrain from using our Platform. By accessing or using our Platform you agree to our use of your information consistent with the Terms of Use and this Privacy Policy.

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Sharing Your Information

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The Developer uses Unity Software to collect data from its players and to manage its games. We collect your device information passively (without you having to give it to us) to better meet our player’s needs.

1: Information probably collected about your device: unique device identifiers (e.g., IDFV for iOS devices and Android ID for Android devices) ); IP address; country of install (mapped from IP address); device manufacturer and model platform type (iOS, Android, Mac, Windows, etc.) and the operating system and version running on your system or device; language; CPU information such as model, the number of CPUs present, frequency, and instruction set support flags; the graphics card type and vendor name; graphics card driver name and version (example: "nv4disp.dll 6.10.93.71"); which graphics API is in use (example: "OpenGL 2.1" or "Direct3D 9.0c"); amount of system and video RAM present; current screen resolution; version of the Unity Editor used to create the game; sensor flags (e.g., device support for gyroscope, touch pressure or accelerometer); application or bundle identification ("app ID") of the game installed; unique advertising identifiers provided for iOS and Android devices (e.g., IDFA or Android Ad ID); and a checksum of all the data that gets sent to verify that it did transmit correctly. The Developer does use Unity’s analytics and ad services which collect additional information.

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2: Unity has collected device information, like IP address and device identifiers, as well as events completed or actions taken within the game, including level, number of credits, time it took you to earn them, metadata about in-game communications and the value and details of purchases. The Developer has ongoing access to this data and to aggregated reports about game activity in general across a number of games. These reports are based, in part, on your game activities, but do not specifically identify you or your device.

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3: Unity Ads has probably collected device information, like IP address and device identifiers,and information regarding the delivery of ads and your interaction with them, all of which may be shared with ad publishers and attribution companies. Unity Ads may also incorporate data derived from the Unity Analytics service in user profiles and use that profile data in order to provide personalized advertising. When Unity provides personalized advertising, it will provide you notice and information about how to opt-out of such interest based advertising.

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4: If the game you are playing uses multiplayer, Unity has probably collected unique device identifiers, IP address (which may be matched to identify approximate location for matchmaking), as well as information regarding games played and match attributes.

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5: Like many other providers of mobile apps instead of requiring users to create an account and log in to it each time they access one of our apps, Unity and others using our products may opt to recognize the user’s device through various device identifiers. Device identifiers are also used for functions that require Unity to recognize devices across various apps. For example, if we want to effectively limit the number of ads a particular device receives, we need to recognize the device across apps and use device identifiers to do so.

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For more information regarding Unity's Privacy Policy, please go to https://unity3d.com/legal/privacy-policy .

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The Developer does not sell, trade, or disclose your Personal Information to third parties except as set forth in this Privacy Policy and as follows:

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To the Google Play Store (https://play.google.com/store?hl=en), the Apple App Store (https://www.apple.com/ios/app-store/), PlayFab (https://playfab.com/), Photon (https://www.photonengine.com/), Unity (https://unity3d.com/) in order to perform our services. Please note that Personal Information collected or disclosed to each Service Provider will be governed by their privacy policy. You must read the privacy policy on each Service Provider website to see how your Personal Information will be handled.

  • To fulfill the purpose for which you provide it.

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.

  • To enforce or apply ourand other agreements, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Developer, our customers, or others.

  • For any other purpose disclosed by us when you provide the information.

  • We may disclose aggregated, non-personally identifiable information about the Platform users without restriction.

 

Retention of Personal Information

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We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax and/or accounting obligations. We do so in accordance with our data retention policies and applicable law.

The Developer does not store your credit card information when you subscribe to our services. The Developer partners with third party providers to process credit card transactions. The Developer processes credit card transactions through the Apple App Store or the Google Play Store. Information about the data security practices of each payment processor can be found on the payment processor’s website.

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Your rights – individuals in the European Union

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If you are an individual in the European Union, you have the right to access, correct, restrict, or erase your Personal Data (as defined in the General Data Protection Regulation) stored on our Platform at any time. You can also exercise any of these rights at any time by contacting us at support@skullwink.com. Your rights include the following:

  • Accessing your data. Upon request, we shall provide any information relating to your data and our processing of your data in a concise, transparent, intelligible, and easily accessible form using clear and plain language. The information shall be provided in writing or by other means, including, where appropriate, by electronic means within 30 days of a written request.

  • Correcting your data. You have the right to ask us to rectify any inaccurate or incomplete Personal Data on our Platform. If we have given your Personal Data to any third parties, we will notify those third parties that the Developer has received a request to rectify your Personal Data, unless doing so proves impossible or involves disproportionate effort. Those third parties should also rectify the Personal Data they hold - however, we are not in a position to audit those third parties to ensure that the rectification has occurred.

  • Erasing your data. You can ask the Developer to erase your Personal Data stored on our Platform. If we receive a request to erase your data, we will ask you if you want your Personal Data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose data we have erased so you may be contacted again by us, should we come into possession of your Personal Data at a later date. 

  • Restricting the use of your data. We only process your Personal Data where we have the legal basis for doing so. You have the right to ask us to suspend or otherwise restrict the processing of your Personal Data where:

  • You challenge the accuracy of the Personal Data;

  • The processing is unlawful but you do not want us to erase it;

  • We no longer need the Personal Data for the purposes of the processing, but you want us to hold it as you need it to establish, exercise, or defend legal claims; or

  • You have objected to our use of your data, but we need to verify whether we have legitimate grounds to use it.

               

  • Withdrawing your consent. Where we are relying on consent to process your Personal Data (for example consent to receive marketing) you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

Information Security

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The Developer has implemented certain procedural, technical and physical security measures to help protect against the risk of loss, misuse, and alteration of sensitive information that you provide. We require third parties with whom we share Personal Information to do the same. Nevertheless, such security measures may not prevent all loss, misuse, or alteration of information on the Platform, and the Developer is not responsible for any damages or liabilities relating to any such security failures. By using the Platform, you understand that there is a risk that data and communications, including email and other electronic communications, may be accessed by unauthorized third parties. The foregoing does not affect any liability that cannot be excluded or limited under applicable law.

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Transfer of Information to the United States

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The Platform is operated in the United States. If you are located outside the United States, please be aware that information we collect, including Personal Information, may be transferred to, processed, and stored in the United States. By using the Platform or providing us with any information, you consent to the transfer, processing, and storage of your information in the United States. You are also consenting to the application of United States federal and Texas state law in all matters concerning the Platform and this Privacy Policy.

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Children’s Privacy

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The Platform is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Platform. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any personal information on the Platform or on or through any of its features/register on the Platform, make any purchases through the Platform, use any of the interactive or public comment features of the Platform or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@skullwink.com.

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Links to Other Materials

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Platform may be linked to and from websites or mobile applications that are not under the control of the Developer. The Developer shall have no responsibility or liability for the content or privacy practices of any such linked website(s) or any link or linking program at any time. If you click on a link on our Platform and link to a third party’s website, then this Privacy Policy will not apply to your Personal Information collected on that third party’s website and you must read the privacy policy on that website to see how your information will be handled.

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Social media widgets or tools may appear on our Platform. Your use of these widgets or tools will be governed by the terms of use and privacy policy of the applicable social media provider (e.g. Facebook®).

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Changes to Our Privacy Policy

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We may update this Privacy Policy to reflect changes in our privacy practices. If we make changes to this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Platform. Those changes will go into effect on the Last Updated date shown in the revised Privacy Policy. Your continued use of our Platform or Services constitutes your consent to the revised Privacy Policy.


Larry Ted McBride

Skullwink Entertianment

 

Written May 15, 2017

Updated May 10, 2019

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