Last update: February 28, 2019
Table of Contents
2. ESRB Privacy Certified
4. How Does Budge Studios Handle Children’s Information?
5. What Information does Budge Studios Collect?
6. How Does Budge Studios Use the Information Collected?
7. How Does Budge Studios Share or Disclose Information?
8. What Should I Know about Third Parties?
9. What Are My Rights and Choices?
10. How Does Budge Studios Protect Information?
11. Does Budge Studios Transfer Information Internationally?
12. How Do I Contact Budge Studios?
13. What Should I Know as a Data Subject in Europe?
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2. ESRB PRIVACY CERTIFIED
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4. HOW DOES BUDGE STUDIOS HANDLE CHILDREN’S INFORMATION?
A. Children’s Use of the Platforms.
If you have any questions or comments about how we treat children’s information or our compliance with COPPA, please contact us as set out in the How Do I Contact Budge Studios? section. If you would like to learn more about COPPA, you can refer to the Children’s Privacy section of the Federal Trade Commission’s website.
B. Sites and Programs.
Budge Studios does not knowingly collect personal information as defined by COPPA from children through its Sites or Programs. If we learn or have reason to suspect that we have collected personal information from a child in violation of COPPA, we will promptly delete it. Parents should note that if they provide information about their child through a Site or Program, COPPA will not apply to that information.
• List of Child Directed Apps.
For a list of Apps that Budge Studios treats as being primarily directed to children under COPPA (“Child Directed Apps”), please contact us as set out in the How Do I Contact Budge Studios? section.
• Collection, Use, and Sharing of Information from Children.
We collect, use and share personal information from children through our Apps as follows:
o Email Contact. On occasion, in order to respond to a question or request from a child through a Child Directed App, Budge Studios may receive or need to ask for the child’s online contact information, such as an email address. Budge Studios will delete this information immediately after responding to the question or request.
o Photos, Videos, and Audio. Our Child Directed Apps may request access to the device’s camera, photo album, or microphone in order to provide in-game functionality. For example, a child may blow into the microphone in order to blow out cartoon candles or take a photo of their arm with a cartoon bracelet and save that image to their local device. Budge Studios does not store or share any photos, videos, or audio files that contain children’s images or voices through our Child Directed Apps. All photos, videos, and audio files are stored locally on the device only.
o Local Notifications. Our Child Directed Apps may allow children to receive local notifications on their devices. This means that the Child Directed App may send notifications to the device at preset times, but will not collect any personal information in connection with the notifications. These notifications may be turned off at any time through device settings. We do not use push notifications in our Child Directed Apps.
o Persistent Identifiers. Budge Studios collects, uses and shares persistent identifiers, such as device identifiers or IP addresses, through our Child Directed Apps solely for the purpose of providing support for the internal operations of the Child Directed Apps or as otherwise permitted by COPPA. This information may be collected by Budge Studios or a third party providing a service to Budge Studios.
o In-App Advertising. Some of our Child Directed Apps incorporate advertising serving technology offered by our third party service providers, which enable advertising to be temporarily uploaded into the game and replaced while the user plays. The data collected for this purpose may include persistent identifiers solely for the purpose of providing support for the internal operations of the Child Directed App as permitted by COPPA, such as allowing our third party service providers to calculate the number of views, cap the frequency of ads and serve ads in a format that fits the device. Please note that while our Child Directed Apps may contain advertisements about Budge Studios or third party products and services, we prohibit behavioral advertising to children in our Child Directed Apps or through data collected from our Child Directed Apps.
We take reasonable measures to maintain the confidentiality, security, and integrity of children’s personal information collected through Child Directed Apps, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security. We retain children’s personal information only as long as necessary to fulfill the purpose for which it was collected, and delete such information using reasonable measures to protect against its unauthorized access or use.
• Parental Choices and Controls
As part of the verifiable parental consent process, where applicable, parents and legal guardians will have the choice of consenting to our collection and internal use of their child’s personal information but prohibiting us from disclosing that information to third parties (except to the extent such disclosure is integral to our Apps). Additionally, any parent has the right to: (1) review, correct, or delete the child’s personal information; and/or (2) discontinue further collection, use, or sharing of the child’s personal information. Please note that exercising these choices may restrict your child’s ability to access certain functionality of the Apps. To exercise any of these choices, please contact us as set out in the How Do I Contact Budge Studios? section.
If you are a parent or guardian and believe that we have collected your child’s personal information in violation of COPPA, please contact us as set out in the How Do I Contact Budge Studios? Section, and we will remove such information to the extent required by COPPA.
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5. WHAT INFORMATION DOES BUDGE STUDIOS COLLECT?
A. Information You Provide.
Budge Studios collects information that you provide on or through the Platforms, including information you provide when you play our games, access our content, participate in a Promotion, subscribe to our newsletters, join our Programs, apply for a job, or contact customer support. We use third party service providers to collect information.
The information we collect includes information that can be used to identify a specific individual (whether alone or in combination). Some examples of information you provide include the following:
- Contact data, including your first and last name, email address, home address, and phone number.
- Demographic data, including your age, gender, preferred language, country and zip code or postal code.
- If you a parent or legal guardian, information about your child such as your child’s first name and last name initial, year of birth, gender, and country of residence.
- Content, including content within any messages you send to us (such as provided in surveys or questions to customer support).
- Resume Data, including your employment history, transcript, writing samples, and references as necessary to consider you for a job opening if you submit an application to us.
You may choose to voluntarily submit other information to us through the Platforms that we do not request, and, in such instances, you are solely responsible for such information.
B. Information Collected Automatically.
- Service Use Data, including information about online activity such as feature usage, game play statistics and in-app purchases.
- Device Connectivity and Configuration Data, including information about hardware, software, platform, media, connection data, your internet service provider, and your device’s regional and language settings. This includes device identifiers such as IP address, MAC address, and Ad Id (e.g., IDFA or AAID).
- Location Data, including location derived from an IP address or data that indicates a city or postal code level. We do not collect precise location data.
We use various current – and later – developed technologies to automatically collect information (“Tracking Technologies”), including the following:
- Log Files, which are files that record events that occur in connection with your use of the Platforms.
- App Technologies, which are technologies included in our Apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our Apps include third party SDKs, which is code that sends information about your use to a server. These SDKs allow us to analyze the performance of our Apps, bring you advertising both on and off the Apps, and provide you with additional functionality. However, for our Child Directed Apps, we do not collect information for behavioral advertising.
For more information on the use of Tracking Technologies within our Platform and your rights and choices regarding Tracking Technologies, see the What Should I Know about Third Parties? and What Are My Rights and Choices? sections below.
C. Information from Other Sources.
o Social networks, when you engage with our content, reference our Platforms, or grant us permission to access information from the social networks.
o Partners, that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
For more information on Third Party Services, see the What Should I Know about Third Parties? section below.
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6. HOW DOES BUDGE STUDIOS USE THE INFORMATION COLLECTED?
Budge Studios uses the information you provide us for the purposes of:
• Managing and optimizing our Platforms, including:
o Enabling your use of our Platforms and access to certain areas of our Sites, Apps or Programs;
o Delivering you customized content;
o Monitoring and analyzing trends, usage, and activities; and
o Diagnosing problems with and improving our Platforms.
• Communicating with you and facilitating your requests, including:
o Responding to your comments, questions and requests, including providing customer support;
o Registering you in a Program such as Budge Playgroup (beta-testing of new Apps);
o Administering Promotions, including verifying eligibility and awarding prizes, which are only directed to adults and non-child users; and
o Subscribing you to Budge Studios’ newsletter, which may include advertisements and communications alerting you to new products, features and enhancements, special offers upgrade opportunities, and contests and events of interest.
• Protecting our Platforms and user rights, including:
o Obtaining verifiable parental consent, as necessary;
o Preventing and addressing fraud, breach of policies or terms, and threats of harm; and
o Sending you technical notices, updates, security alerts, information regarding changes to our polices, and support and administrative messages.
• Advertising, including:
o Developing and providing you with direct marketing, including advertisements about our and third party products, offers, promotions, rewards, events, and services; and
o Serving advertising tailored to your interests, which is not collected from information collected through Child Directed Apps.
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7. HOW DOES BUDGE STUDIOS SHARE OR DISCLOSE INFORMATION?
• Partners. Budge Studios shares information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
• Contests, Sweepstakes and Promotions. If you voluntarily enter a contest, sweepstake or promotion (“Promotion”), we share information with third parties as set out in the official rules that govern the Promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, you agree to the official rules of that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials. Unless specifically indicated with additional terms, Promotions are only directed to adults and non-child users.
• Business Transactions. We reserve the right to transfer any information we have about you in connection with the sale or transfer of all or a portion of our business or assets or rights relating thereto.
• Affiliates. We may share information with our affiliates for their own business purposes.
• Legal Rights and Obligations. We may use and/or disclose your information to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage. When necessary, we may also disclose information to law enforcement, or to the appropriate civil authorities.
Notwithstanding the above, Budge Studios may share or disclose information that does not identify you (including information that has been aggregated and de-identified) with third parties except as prohibited by applicable law. For more information on your rights and choices regarding how we share information about you, please see the What Are My Rights and Choices? section below.
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8. WHAT SHOULD I KNOW ABOUT THIRD PARTIES?
A. Third Party Services.
B. Third Party Features.
C. Analytics and Advertising.
Our Sites and Apps contain Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics provides, such as Google Analytics, to help us analyze your use of the Sites and Apps, compile statistic reports on the Site’s and Apps’ activity, and provide us with other services relating to Site and App activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Sites, Apps, and/or on Third Party Services. These third parties may use Tracking Technologies on our Sites, Apps, and Third Party Services (including in emails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Sites, Apps, and Third Party Services or third party devices after you have left them (“behavioral advertising”).
We do not engage in behavioral advertising in our Child Directed Apps. For further information on advertising in Child Directed Apps, please see the How Does Budge Studios Handle Children’s Information? section above.
For further information on Tracking Technologies and your rights and choices regarding them, please see the Information Collected Automatically and What Are My Rights and Choices? sections.
D. Advertising with SuperAwesome.
Our Apps may display advertisements served by SuperAwesome Trading Limited (“SuperAwesome”), a provider of kid-safe advertising services that are designed specifically for the compliance requirements of younger audiences, including those aged under 13. SuperAwesome places contextual advertising on Apps without collecting any personally identifiable information, including persistent identifiers.
SuperAwesome is certified as COPPA-compliant by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. Please go to www.kidsafeseal.com for more information.
SuperAwesome is a valid licensee, and participating member, of ESRB Privacy Certified. To protect your privacy, SuperAwesome has voluntarily undertaken this privacy initiative, and its services have been reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, SuperAwesome’s services are subject to frequent audits and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.
SuperAwesome also provides advertising services in compliance with the General Data Protection Regulation (EU 1996/679). Adopting an approach of ‘privacy by design and by default’, SuperAwesome utilises proprietary technologies so that it neither collects, stores nor shares your personal data to provision advertisements or target advertising to you.
You may contact SuperAwesome directly at email@example.com on + 44 203 668 6677, or by post: Privacy Team, SuperAwesome Trading Limited, 8 Duncannon Street, London, England, WC2N 4JF, United Kingdom.
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9. WHAT ARE MY RIGHTS AND CHOICES?
A. Reviewing, Correcting and Deleting Your Information.
If you believe we have collected and stored any personal information from children under 13 in violation of COPPA, parents or legal guardians can request access to review such information, have it deleted, or stop our further collection or use of such information. To make any of these requests (when applicable), please contact us as set out in the How Do I Contact Budge Studios? section below.
B. Tracking Technology Choices.
• App Technologies. You can stop all collection of information via an App by uninstalling the App. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you.
Please be aware that if you disable or remove Tracking Technologies some parts of the Platforms may not function correctly.
C. Analytics and Behavioral Advertising.
Our Sites use third party tools such as Google Analytics, Facebook, YouTube and Vimeo. These third party tools collect data through Tracking Technologies such as cookies, which may be used in accordance with their privacy policies. Please refer to the privacy policies of these third parties to learn more about their practices and available opt-outs.
For Google Analytics, you can find their opt-out by visiting: https://tools.google.com/dlpage/gaoptout?hl=en-GB and downloading the Google Analytics Opt-Out Browser Add-on.
Where we work with third parties to engage in behavioral advertising, these third parties are often members of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative ("NAI"). These programs offer centralized locations where users can make choices about the use of their information for behavioral advertising. To learn more about the DAA’s Self-Regulatory Program for Online Behavioral Advertising and your opt-out options for their members, please visit (i) for website opt-out, https://www.aboutads.info/choices; and (ii) for mobile app opt-out, https://www.aboutads.info/appchoices. To learn more about the NAI and your opt-out options for their members, please visit https://www.networkadvertising.org/choices/.
Please note that any opt-outs only apply to the specific browser or device from which you opt-out. Further, opting-out through the DAA or NAI only means that the selected members should no longer deliver certain behavioral advertising to you, and does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their practices or programs.
• E-mails. You may opt out of receiving promotional emails from us at any time by contacting us as described in the How Do I Contact Budge Studios? section below or by using the unsubscribe mechanism included in the email communications you receive. Please note that you cannot opt-out of non-promotional emails, such as those about your transactions, servicing, or Budge Studios’ ongoing business relations.
• Local or Push Notifications. If you have opted-in to receive local or push notifications on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app. In Child Directed Apps, Budge Studios only uses local notifications.
Please note that your opt-out is limited to the email address or device used and will not affect subsequent subscriptions.
E. Your California Privacy Rights.
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set out in the How Do I Contact Budge Studios? section below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Budge Studios is not required to respond to requests made by means other than through the provided email address or mail address.
F. Your European Privacy Rights.
Data subjects in Europe have additional rights as set out in the What Should I Know as a Data Subject in Europe? section below.
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10. HOW DOES BUDGE STUDIOS PROTECT INFORMATION?
We maintain reasonable and appropriate safeguards designed to help protect the security, integrity, accuracy and privacy of the information you have provided. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
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11. DOES BUDGE STUDIOS TRANSFER INFORMATION INTERNATIONALLY?
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12. HOW DO I CONTACT BUDGE STUDIOS?
Attention: Data Protection Officer
5455, De Gaspé Avenue, Suite 540
Montreal, QC, H2T 3B3, Canada
For complaints, you can also contact ESRB Privacy at ESRB Attn: Privacy Certified Program, 420 Lexington Avenue, Suite 2240 New York, New York 10170, by email at firstname.lastname@example.org, or directly through their consumer hotline.
Data Subjects Located in the EU:
For European specific requests, you can use any of the methods above or as further specified in the What Should I Know as a Data Subject in Europe? section below.
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13. WHAT SHOULD I KNOW AS A DATA SUBJECT IN EUROPE?
A. Budge Studios is a Data Controller.
Data protection laws in Europe make a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Budge Studios acts as a controller with respect to personal data collected as you interact with our apps, websites, emails, and advertisements.
B. Budge Studios has a Lawful Basis for Processing.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. We retain personal data for as long as necessary to fulfill the purpose for which it was collected, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.
C. Your European Privacy Rights.
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
You may exercise your rights by submitting a written request to us at the address set out in the How Do I Contact Budge Studios? section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
D. Children in Europe.
If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us.
In addition to the contact information above, please contact our Data Protection Officer at email@example.com
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