Privacy Statement of Creative Friends B.V.

This Privacy Policy will be effective from May 24, 2018.

Through its online game, WordCrex will process privacy-sensitive or personal data. Creative Friends B.V. values the privacy of its customers and observes due care in processing and protecting personal data. We process data in compliance with the requirements laid down by the Dutch Personal Data Protection Act (DPDA). Creative Friends B.V. is the party responsible for all data processing. Our data processing registration with the Dutch Data Protection Authority is filed under number M1574527. In this privacy statement, we will explain which personal data we collect and for which purposes. We recommend that you read it carefully. Please read this Creative Friends BV Privacy Policy before using any Creative Friends BV service because it will tell you how we collect, store, use and disclose your personal information when providing these services to you. The following Privacy Policy applies to all games of Creative Friends BV (the “Game”) as well as any and all related web sites. If you have questions or complaints regarding our Privacy Policy or practices, please contact us at info@creativefriends.eu.

1 INTRODUCTION
Creative Friends BV develops and publishes social games for both web and mobile devices. “Creative Friends BV,” or “we” or “us” refers to Creative Friends BV.

This Privacy Policy applies whenever you play our games or otherwise access any of our other products, services, content and/or the other domains provided by Creative Friends BV, together referred to as “Services.” This Privacy Policy describes:

    • 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

If you do not want Creative Friends BV to collect, store, use or share your information in the ways described in this Privacy Policy, you may not play Creative Friends BV games or use Creative Friends BV Services.

The following Privacy Policy applies to all games of Creative Friends BV (the “Game”) as well as any and all related web sites.

2 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 play Creative Friends games 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, Creative Friends BV may receive certain information about you from the provider of the third-party application. The information we receive depends on the Creative Friends BV game you’re playing, the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.

When you sign up to post in one of our forums or participate in any other manner, you may grant access to certain information such as your email address, your name, a unique user name, or other information you share, either directly or by granting access to your user account on social network such as Facebook or Google+. This and any other Personally Identifiable Information you provide, directly or indirectly, is collectively referred to as your “PII,” and is used to facilitate and enhance your player experience.

For example, Creative Friends BV 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 Creative Friends BV.

If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Policy.

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 Firebase, 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; and
    • tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively.

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
      game state and the date and time of activity on our websites or games.

In some cases, we will connect this information with your social network ID or Creative Friends BV user ID.

Please note that companies delivering advertisements on our Services may also use cookies or other technologies as described below in Third Party Advertising Including Tailored Advertising and Analytics, and those practices are subject to those companies’ own policies.

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 play Creative Friends BV games on your mobile device, in addition to your device identifiers, we may also collect:

    • the name you have associated with your device;
    • your country;
    • your specific geolocation;
    • information about Creative Friends BV 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
When you use our Services (whether through a social network or through Creative Friends BV directly), you may give us information directly (like when you’re setting up your account) and we will store that on our systems and use it for the purposes described in this Privacy Policy.Some games or parts of our Services may use a more traditional registration or account setup 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 Creative Friends BV players can see. Your player profile may include information like:

    • a profile photo;
    • game username(s);
    • 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 games you play; and
    • a Creative Friends BV player ID number that is created by Creative Friends BV and used to identify your profile.

Certain information from your Creative Friends BV profile may be publicly accessible on Creative Friends’s websites that offer direct access to Creative Friends BV games, including:

    • The Creative Friends BV player ID;
    • Game username(s);
    • Your first and last names; and
    • Your player profile picture.

Information About Your Contacts
We do give you the ability to import your address book contacts or enter them manually. We do so only with your permission. You are able to invite and connect with friends using third-party 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 players using our games that are connected to you.

Information You Generate Using Our Communications Features
Except for games 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 Creative Friends, but also with other Creative Friends BV 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 Creative Friends servers to make use of them to protect the safety and well-being of our players and Creative Friends 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.

Payment Information
If you purchase a license to use in-game virtual currency or virtual items in a game you play from Creative Friends, 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. Creative Friends BV does not collect or store your financial information, like credit card numbers. However, Creative Friends’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. Creative Friends BV 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 Creative Friends BV 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 games 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.

Other Sources
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.

3 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 players’ experiences;
    • to create your game accounts and allow you to play our games;
    • to identify and suggest connections with other Creative Friends BV players and personalize our Services to you;
    • to enable players to communicate with each other;
    • to provide technical support and respond to player inquiries;
    • to protect the safety and well-being of our players;
    • to protect Creative Friends 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 email address to Creative Friends, 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 “Player X played a word” as well as tell you about gift and neighbour 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 email messages and push notifications (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 Creative Friends BV having certain contact information from you. If you play one of our games 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.

4 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 Amsterdam) 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 Creative Friends ) or allow third parties to collect this information from our Services in the following circumstances:

Your Consent
With your consent, we may share your information with third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy.

Friends and Other Creative Friends BV Players
The Service supports and often encourages you to interact with other players. In most Creative Friends BV games, if you play through a social network or register through a social network (for example, Facebook Connect), your social network friends will see your name, profile photo and descriptions of your game activity. Similarly, in many Creative Friends BV games, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity (including the identification of any Creative Friends BV games you have played), communicate with you within our Services, and view your game profile, which may include your name or a “game name” and your profile photo. For example, in Creative Friends’s WordCrex, any other player may see your game profile if you are playing against them. In certain cases, your profile photo can reveal your social network ID or Creative Friends BV player ID, and access to a social network ID or Creative Friends BV player ID may allow others to view the public information associated with your related social network profile or Creative Friends BV account. Other players may also be able to send you game requests through the related social network’s or Creative Friends’s communication channels.

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 Amsterdam);
    • 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 Creative Friends BV or the social network through which you are playing Creative Friends games.

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 Creative Friends BV games designed for children under 13, though Creative Friends BV 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 Creative Friends BV may 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 Creative Friends BV and other applicable third parties, including to enforce our Terms of Service.

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.

Sale or Merger
In the event that Creative Friends BV undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part its assets (like selling a game), we may disclose or transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to let you and other players know (in the way described in Changes to Our Privacy Policy) of the business transition before transferring your personal information.

5 HOW TO ACCESS, UPDATE AND MANAGE YOUR INFORMATION
Information We Receive From a Third-Party Application Where You Play Our Games or From Your Mobile Device
To manage the information Creative Friends BV receives about you from a third-party application where you play our games, 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. (https://www.facebook.com/settings/?tab=applications). To review and update information associated with your Creative Friends BV game profile in certain games, visit the “settings” page in that game. 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.”

Once Creative Friends BV receives your information from a third-party application or your mobile device, that information is stored and used by Creative Friends BV in accordance with this Privacy Policy. You may access and update that information as described below.

Accessing and Updating Your Information Held by Creative Friends
If you want to review, delete, or change the information Creative Friends has about you or have additional questions, use the in-game setting features or send us an request at info@creativefriends.eu. We will respond to your request within thirty days.

Stopping Use of Your Information
If you no longer want Creative Friends BV to make active use of your information, you can contact us at the email given under the in-game info sections or send an email to info@creativefriends.eu.

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.

Opting Out of Promotional Emails from Creative Friends
If you want to stop receiving promotional emails from Creative Friends, click on the “unsubscribe” link in any promotional email from Creative Friends BV. 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
When you install our apps on your mobile device you can choose to receive local notifications and 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.
If at any time you indicate that you no longer want to receive communications from Creative Friends, or if you wish to cancel your account, or to change or correct any of your PII, you are free to do so and your PII will be deleted, changed, or corrected as requested.

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:

and

These opt-out tools are provided by third parties, not Creative Friends. Creative Friends BV 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-out 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 Creative Friends. Creative Friends BV 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 Creative Friends’s games 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. If you disable cookies, you may lose some of the features and functionality of our Services because Creative Friends BV cookies are necessary to track and enhance your game activities.

6 PRIVACY POLICIES OF LINKED THIRD PARTY SERVICES AND ADVERTISERS
Our websites and games may contain advertisements from Third-Party Services, which are companies other than Creative Friends BV 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.

7 OUR POLICIES CONCERNING CHILDREN
Most of our games are for people of all ages and we do not knowingly collect any personal information from children under 13 years old unless strictly needed. If Creative Friends BV learns that a child under the age of 13 has provided us with personal information that is not subject to a COPPA exception, Creative Friends BV will delete such information. This may result in a loss of player profile or blocked access to a Game.

8 LOG DATA
Our servers automatically record information (“Log Data”) created by your use of the Services. Log Data may include information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive Log Data when you interact with our Services, for example, when playing a Game, or interacting with our notifications.

Only qualified staff and our trusted operational partners, who help Creative Friends to deliver and service the Game, have access to your PII. Creative Friends WILL NOT share your PII with anyone else or any other organization. Your PII WILL NEVER be sold or distributed in any form or for any other purpose unless approved by you.

9 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.

10 SECURITY OF YOUR INFORMATION
We implement security measures to help protect the security of your information both online and offline. We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your 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 services, please contact us at info@creativefriends.eu

11 CHANGES TO OUR PRIVACY POLICY
The privacy policy may change over time. We will post the updated privacy policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us.

12 CONTACT US
If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an email to info@creativefriends.eu

Creative Friends BV
Prins Hendrikstraat 60
4835 PL
Breda

In addition, Creative Friends may also offer you the opportunity to “opt in” to receive additional email communications, including Creative Friends News Releases related to all the latest-breaking news, the launch of new Creative Friends games, and announcements of all new Creative Friends Games options and features.

13 CHOICE OF LAW
When reading a translated copy of this privacy policy, the original English version is leading.

In the unlikely event that we cannot solve your concern and you wish to bring legal action against us these terms shall be governed by and construed in accordance with the laws of The Netherlands.