Table of Contents
2. Information We Collect and How We Collect It
3. How We Use the Information We Collect
4. How We Share Your Information
5. How to Access, Update and Manage Your Information
6. California Online Privacy Protection Act Notice
7. Privacy Policies of Third Party Services and Advertisers
8. Our Policies Concerning Children
9. International Operations and Transfers Out of Switzerland and the EEA
10. How Long We Keep Your Information
11. Security of Your Information
13. Contact Us
- what information we collect, how we collect it, and why
- how we use that information and with whom we share it
- how you can access and update that information
- the choices you can make about how we collect, use, and share your information
- how we protect the information we store about you
Information We Collect and How We Collect It
Information About You That We Get From Connected Third-Party Applications, Including Social Networks (like Facebook)
If you Stepboard’s app or access any of our other Services on connected third-party applications or connect our Services to any third-party applications, including social networks like Facebook,Stepboard may receive certain information about you from the provider of the third-party application. The information we receive depends on the Stepboard app you’re using, the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.
For example,Stepboard may collect and store some or all of the following information shared by the provider of the connected third-party application:
- your first and last name;
- your profile picture or its URL;
- your user ID number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;
- the user ID number and other public data for your friends;
- the login e-mail you provided to that third-party application when you registered with it;
- your physical location and that of the devices you use to access our Services;
- your gender;
- your birthday and/or age range;
- information about your activities on or through the connected third-party application;
- other publicly-available information on the third-party application; and/or
- any other information that you or the provider of the third-party application share with Stepboard.
If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.
Cookies and Automated Information Collection
We and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:
- cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;
- web beacons, which let us know if a certain page was visited or whether an e-mail was opened;
- tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively; and
- local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times.
We and our service providers use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:
- IP addresses;
- the type of computer or mobile device you are using;
- your operating system version;
- your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
- your browser types;
- your browser language;
- referring and exit pages, and URLs;
- platform type;
- the number of clicks on a page or feature;
- domain names;
- landing pages;
- pages viewed and the order of those pages;
- the amount of time spent on particular pages; and
- app state and the date and time of activity on our websites or apps.
In some cases, we will connect this information with your social network ID or Stepboard user ID.
For more information on how to limit the types of cookies you allow, please see Opting out of Cookie Tracking.
Other Information from Your Mobile Device
If you use Stepboard on your mobile device, in addition to your device identifiers, we may also collect:
- the name you have associated with your device;
- your telephone number;
- your country; and
- your specific geolocation;
- your mobile contacts (as further described below in “Information About Your Contacts”); and
- information about Stepboard and other third-party apps you have on your device.
If you want to adjust your privacy preferences on your mobile device, please see How to Access, Update and Manage Your Information.
Information About You That You Share With Us Directly
Some parts of our Services may use a more traditional registration or account set-up process where you may be asked to give us some or all of the following information:
- your age or birthday;
- your first and last names;
- your e-mail address;
- a password; and
- other information that helps us make sure it’s you accessing your account or helps us improve our services.
We may also let you create a player profile, separate from your social networking site profile (for example, your Facebook profile), that other Stepboard users can see. Your player profile may include information like:
- a profile photo;
- your gender;
- biographic details (like your age or age range);
- approximate location information that you provide;
- links to your profiles on various social network;
- details about the apps you use; and
- a Stepboard player ID number that is created byStepboard and used to identify your profile.
Certain information in yourStepboard profile may be publicly accessible on Stepboard’s websites that offer direct access to the Stepboard app, including:
- The Stepboard player ID;
- Your first and last names; and
- Your player profile picture.
Except for apps designed for children under 13, your Stepboard player ID number used to identify your account and player profile will appear in the URL of your profile page. It will only allow access to information you make public in your settings.
Information About Your Contacts
We may give you the ability to import your address book contacts or manually enter them so that you can locate your contacts on Stepboard and invite them to join you in our apps or other aspects of our Services. You are responsible for getting your contacts’ permission when you opt to give their contact details to us. We may also get information about you from other Stepboard users importing or entering their contacts. We use and may store this contact information to help you and your contacts connect through our Services. If you want to remove your contacts stored by us, follow the instructions provided in the game to request that we remove them from our systems. If you need to enter a password to allow us to access your address book, we will not store that password.
Information You Generate Using Our Communications Features
Except for apps designed for children under 13, you may be able to take part in certain activities on our Service that let you communicate or share information not just with Stepboard, but also with other Stepboard players. These include:
- participating in player forums and message boards;
- posting public comments to other players’ profiles or gameboards;
- sending private messages or invitations to other players, either directly on our websites or to their e-mail accounts;
- chatting with other players; and/or
- posting photos or drawings.
You acknowledge and expressly agree that we may access in real-time, record and/or store archives of these communications, comments, photos and drawings on Stepboard’s servers to make use of them to protect the safety and well-being of our users and Stepboard’s rights and property in connection with our Services; to conduct research; to operate, improve, personalize and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver contextual advertising.
If you purchase a license to use in-game virtual currency or virtual items in a game you play on Paperpeoplespellingbee.com, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information.Stepboard does not collect or store your financial information, like credit card numbers. However, Stepboard’s payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased in order to fulfill your order. Stepboard may also obtain the billing and payment information that you provide when your purchase is processed by someone else (like Facebook, Apple or Google) such as when you purchase something in a game you play on a social network or that you downloaded on your mobile device. Our Terms of Service explain our policies and terms relevant to our charges, billing practices, third-party credits and virtual currencies. Please note that purchases of third party credits or currencies may also be subject to those parties’ policies.
Customer Support Correspondence
Except as provided herein, when you ask for help from our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your game play or activity on our Services, and your Stepboard player and/or social network ID number. We will also store the communications you have with the Customer Service team and any information in those communications in order to provide support and improve the Services. For users of our apps designed for children under 13, we will use your contact information for the sole purpose of providing a one-time response to your question. We will then delete your information from our servers.
Information You Give Us For Text Messaging Services
We receive and store the information you provide, including your mobile telephone number, when you choose to sign up to receive SMS messages.
We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.
If you would like to learn more about how we secure your information, please see Security of Your Information.
How We Use the Information We Collect
The main use of the information we collect and store is to provide a better gaming experience, but there are other uses as well. The uses for which we collect and store your information include:
- to operate, improve and optimize our Services and our users’ experiences;
- to create your user accounts and allow you to use our apps;
- to identify and suggest connections with other Stepboard users and personalize our Services to you;
- to enable players to communicate with each other;
- to provide technical support and respond to users inquiries;
- to protect the safety and well-being of our users;
- to protect Stepboard’s rights and property in connection with our Services;
- to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
- to manage and deliver contextual and behavioral advertising;
- to notify players of in-game updates, new products or promotional offers;
- to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and
- to conduct research.
One important use of your information is communication. If you have provided your e-mail address to Stepboard, we will use it to respond to customer support inquiries, and keep you informed of your in-game activity, including comments from friends, let you know about in-game status such as “crops ready” as well as tell you about gift and neighbor requests. Some messages, like invites for friends to join you in a game, may include your name and profile photo. We may also send promotional e-mail messages and promotional SMS messages (e.g. text messages) (“Promotional Communications”) directly or in partnership with other parties, in accordance with your marketing preferences. Each Promotional Communication will offer you choices about receiving additional messages. Receipt of such communications depends on Stepboard having certain contact information from you. If you apps designed for children under 13, you will not be able to provide us with certain contact information. Please see the section on Our Policies Concerning Children for more information.
How We Share Your Information
We may disclose or publish aggregated information (information about you and other players collectively that is not intended to specifically identify you, for example, players between the ages of 21 and 25 who live San Francisco) and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.
In addition, we may share your information (which may include personal information) with third parties (in other words, parties other than Stepboard) or allow third parties to collect this information from our Services in the following circumstances:
Friends and Other Stepboard Useres
The Service supports and often encourages you to interact with other users. If you register through a social network (for example, Facebook Connect), your social network friends will see your name, profile photo and descriptions of your activity. Similarly, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your activity , communicate with you within our Services, and view your game profile, which may include your name or a “game name” and your profile photo.
Third-Party Advertising Including Tailored Advertising and Analytics
We have advertising on our Services so we can continue to offer many of our Services for free.
We do not actively share personal information with third-party advertisers for their direct marketing purposes unless you give us your consent.
When advertisers or ad networks place ads in our Services, they may collect or we may share the following types of information from within our Services:
- performance data (like the number of clicks on an advertisement);
- aggregated and/or de-identified information about you and other players collectively that is not intended to specifically identify you (like players between the ages of 21 and 25 who live San Francisco);
- certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and de-identified persistent device identifiers such as a hashed Android ID);
- your social network ID;
- and other contextual data about your game play (for example, your level and session length).
The information collected may be used to:
- measure how effective ads are, to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising), and/or
- undertake web analytics (like Google Analytics which is used to analyze traffic and other player activity to improve your experience).
Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time.
Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by Stepboard or the social network through which you are using the Stepboard app.
If you do not want to receive tailored in-application advertisements from third parties, please see How to Access, Update and Manage Your Information. Please note that no tailored advertisements will be delivered for Stepboard users designed for children under 13, though Stepboard may allow contextual advertisements to be displayed.
Safety, Security and Compliance with Law
Your information, and the contents of all of your online communications in our Services and between You and Stepboardmay be accessed and monitored as needed to provide our Service and may be disclosed:
- when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena);
- to satisfy any laws or regulations that apply;
- where we believe in our sole discretion that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
- when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and
- to protect the rights or property of Stepboard and other applicable third parties, including to enforce our Terms of Service.
Stepboard may display an “offer wall” that is hosted by an offer wall provider. The offer wall allows third-party advertisers to provide virtual currency to players in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These offers are not made by Stepboard. These offers may be shown to you based on certain technical information, like your geographic area or de-identified demographic information. After clicking on one of these offers, you will no longer be on a site hosted by Stepboard or the social network through which you are using the Stepboard app. To properly credit player accounts and to prevent fraud, a unique identifier, in some cases your social network ID or Delirium player ID, will be shared with the offer wall provider.
Third-Party Service Providers
We will share your information with third-party companies to perform services on our behalf, like processing payments, analyzing data, optimizing game play, e-mail delivery, hosting services, customer service and to help us in our marketing efforts, including managing and delivering contextual and tailored advertisements. We contractually require these third-party service providers to maintain the confidentiality of the information we share with them, and we contractually require them not use your information for anything other than to provide services on our behalf.
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How to Access, Update and Manage Your Information
Information We Receive From a Third-Party Application Where You User our Apps or From Your Mobile Device
To manage the information Stepboard receives about you from a third-party application where you use our apps, like Facebook, you will need to follow the instructions for the third-party application for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here. To review and update information associated with your Stepboard user profile, visit the “settings” page in that app. You also can manage some aspects of information collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.”
Accessing and Updating Your Information Held b yStepboard
If you want to review, delete, or change the information Stepboard has about you or have additional questions, e-mail us at firstname.lastname@example.org We will respond to your request within thirty days.
Stopping Use of Your Information
If you no longer wantStepboard to make active use of your information, you may send an e-mail to email@example.com Place “Delete My Account” in the subject line and include your first name, last name, e-mail address and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail (for example, your Facebook user ID). We will respond to your request within thirty days. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have sent content through or posted content on the Service, we may not be able to delete it.
Opting Out of Geolocation
If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device’s settings for the relevant application or the “settings” page for the relevant game.
Opting Out of Promotional Emails from Stepboard
If you want to stop receiving promotional e-mails from Stepboard, click on the “unsubscribe” link in any promotional email from Stepboard or visit the e-mail preference page. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, and in no event longer than ten business days.
Opting Out of Other Communications
You can opt out of receiving SMS messages (for example, text messages) by texting back STOP to the number we send the text from for that particular SMS message program. In some cases a preferences management page will also be available. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.
When you install our apps on your mobile device you can choose to receive push notifications, which are messages an app sends you on your mobile device even when the app is not on. You can turn off notifications by visiting your mobile device’s “settings” page.
Opting Out of Third-Party Tailored Advertising
If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web and mobile web advertising you may visit the following websites:
- Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising; and
- Your Online Choices UK website for EU-based advertising.
These opt-out tools are provided by third parties, not Stepboard. Stepboard does not control or operate these tools or the choices that advertisers and others provide through these tools.
In addition, if you do not want to receive tailored in-application advertisements from third parties that relate to your interests in apps on your mobile device, you may opt- ut by adjusting the ad tracking settings on your device. You can also reset the “Advertising Identifier” (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not Stepboard. Stepboard does not control or operate these tools or the choices that advertisers and others provide through these tools.
Please note that you may still receive advertisements from third parties within the Stepboard app even if you opt out of tailored advertising but they will not be based on your activity across unrelated web sites or apps.
Opting Out of Cookie Tracking
You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
If you disable cookies, you may lose some of the features and functionality of our Services because Stepboard cookies are necessary to track and enhance your game activities.
California Online Privacy Protection Act Notice
At this time, there is no general agreement on how companies like Stepboard should interpret Do Not Track signals. Stepboard does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device. You can learn more about Do Not Track here.
Privacy Policies of Linked Third-Party Services and Advertisers
Our websites and apps may contain advertisements from Third-Party Services, which are companies other than Stepboard that may link to their own websites, online services or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.
Our Policies Concerning Children
Most of our websites and apps are not for children under the age of 13 and we do not knowingly collect any personal information from children under 13. Children under 13 should not use these websites or apps at any time. If we learn that we have inadvertently gathered personal information from a child under 13, we will take reasonable measures to promptly remove that information from our records.
Stepboard provides health tracking service which is intended to be enjoyed by parents, teachers, and children of all ages. Stepboard may also provide which are intended for users of all ages. Stepboard does not knowingly collect personal information (as that term is defined under the Children’s Online Privacy Protection Act (COPPA)) from users under the age of 13, except as permitted by COPPA. For example, Stepboard may collect persistent identifiers to support the internal operations of its apps. If Delirium learns that a child under the age of 13 has provided us with personal information that is not subject to a COPPA exception, Stepboard will delete such information.
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International Operations and Transfers Out of Switzerland and the EEA
IMPORTANT: When you use Our Services, your data may be sent to the United States and possibly other countries.
If you don’t live in the United States, Octofly, LLC. will control your personal data.
As part of our international operations, we may transfer data to our Affiliates (which means subsidiaries, parent companies, joint ventures and other corporate entities under common ownership with Octofly, LLC.) from time to time for our legitimate business purposes. For example, Octofly, LLC. provides certain services to its Affiliates.
We store information about players and visitors to our sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. Personal data collected within Switzerland and the European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of Switzerland and the EEA. The data we hold may also be processed by employees operating outside of Switzerland and the EEA who work for us or one of our Affiliates or for one of our vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
Stepboard has certified compliance with the EU-U.S. Privacy Shield, effective as of the date our certification is posted at https://www.privacyshield.gov/list. We adhere to the relevant Privacy Shield Principles for all personal data received from participating European countries in reliance on the Privacy Shield framework.
How Long We Keep Your Information
How long we retain your information depends on why we collected it and how we use it. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements. For instance, we may retain some information for a few years after you have closed your account with us if this is necessary to meet our legal obligations or to exercise, defend or establish legal rights.
Security of Your Information
If you have an account registered directly with Delirium, your profile information is protected by the password you use to access your Delirium account. It is important that you protect and maintain your Delirium account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your Delirium account, the Service allows you to request that instructions be sent to you that explain how to reset your password. If you access our Services through a social network and your social network account is hacked, this may lead to someone using your Stepboard app without your permission. So, be careful to keep your social network account information, including your social network account password, secure as well. We urge you to log out of your Stepboard account and any social network account you have used to access our Services after you use it.
When you sign into your Stepboard account or enter payment information, we or our third party payment processor use encryption to transmit that information.
While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please contact us at firstname.lastname@example.org (link sends e-mail).