FLOWING LIGHTS PRIVACY POLICY

Hi! We are gFaUmNe Inc. (“we” or “GFaUmNe”), the entity that created the Flowing Lights game (the “Game”). We also operate the websites FlowingLights.com and gFaUmNe.com (the “Websites”). We take protecting your personal information seriously and undertake to protect it and use it only for the purposes for which it is collected. The purpose of this policy is to provide you with information on our privacy practices.

By accessing and playing the Game and/or by visiting our Websites, you agree to this policy. More specifically, by accessing and playing the Game, and/or by visiting our Websites you expressly agree to the information that you provide being collected and used for the purposes hereinafter mentioned, in addition to other purposes to which you have expressly agreed. This policy is an integral part of the Game Terms of Use. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT PLAY THE GAME AND DO NOT VISIT OUR WEBSITES.

YOU MUST BE 16 YEARS OF AGE OR OLDER TO USE AND ACCESS THE GAME AND HAVE THE LEGAL CAPACITY TO ENTER THIS CONTRACT.

This policy applies to all information that we may be collecting through the Game or the Websites when you access and play the Game, or visit the Websites.

We may make changes to this policy from time to time. You will receive reasonable notice of any significant changes.

1. Third-Party Logins

When downloading the Game and playing it, you do so through third-party platform or service (“Third-Party Service”). This may include the option to register or log into an account using Steam, Microsoft/Xbox Live or Nintendo Switch/Nintendo NEX or another Third-Party Service. By doing so, you may provide such Third-Party Service with access to certain information such as your social media profile, name, player name, password, email address, avatar/photo, gender, financial/payment information, score and game history information, etc. Please be aware that these Third-Party Services are not subject to this policy, and we are not responsible for their practices. You should review the applicable Third-Party Services’ privacy policies before using their tools to interact with the Game. However, please note that for giving you access to the Game, those Third-Party Services might share some of your information with us, such as your device ID, user ID, partial IP address, approximate location, dates and duration of Game session.

2. INFORMATION COLLECTED IN THE GAME

We do not collect any information that identifies you personally when you access and play the Game. The information we may collect is Game level launched, option used in the Game menu, score, amount of success or failure of a Game challenge, Game crashes and failure.

We also use PlayFab and/or GameAnalytics to collect certain data about your use of the Game, such as your interaction with the Game and the features used or sections visited. We can, furthermore, collect certain data about interruptions, downtimes, failures and malfunctions of the Game, information about your device (e.g.: the type of device used and its operating system) and the time when such events occurred. This data is pre-aggregated; meaning none of the data collected in this way allows us to identify you personally.

3. PURPOSES FOR WHICH THE INFORMATION IS GATHERED

The aforementioned information is collected and used in particular in order to:

• Address problems that are reported to us; and
• Evaluate and improve our Game to make it better suited or more useful to users.

We use the information only for the purposes for which it was collected.

4. DISCLOSURE OF THE INFORMATION

We may mandate third-party service providers to work with us to manage the Game and provide all or part of the services. If so, they will process your information on our behalf and only for the purpose of providing services on our behalf in accordance with this policy. For example, we may mandate service providers for one or more of the following purposes: running, operating and maintaining the Game, performing failure analyses, providing technical support, etc. We limit the information that we share with such service providers to only that which is reasonably necessary to enable them to perform their duties, and the contracts that we enter into with such service providers require that they undertake to keep this information confidential. In all cases, we will require that such third parties undertake to protect your information to at least the same degree that is provided for in this policy.

We may also need to disclose certain information to:

• Government authorities and law enforcement agencies, where required by applicable laws. For example, we may disclose personal and other information if we are required to do so by law or if we believe in good faith that such disclosure is necessary to comply with applicable laws, a court order, a subpoena or a government search warrant, or otherwise to cooperate with such government authorities and law enforcement agencies.
• A purchaser, successor or assignee as part of any merger, acquisition, debt financing, sales of assets or similar transaction, as well as in the event of insolvency, bankruptcy or receivership involving the transfer of personal information as business assets to one or more third parties.

5. RETENTION OF THE INFORMATION

We will retain information about you only as long as necessary for the purposes set out in this policy and to comply with our legal and regulatory obligations. All data is stored on servers with advanced encryption, protected against misuse and access from unauthorized individuals.

Please be aware that information we collect may be transferred, processed, stored, and used internationally, including in the United States, Canada, the United Kingdom, and the European Union. The data protection laws in these countries may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement. By using the Game, or providing us with any information, you consent to the transfer to, and processing, usage, sharing, and storage of your information, including personal data, in other countries as set forth in this policy.

Despite the foregoing, data may transit through other territories and gFaUmNe has no control over this aspect of data transmission.

6. THIRD PARTIES and hyperlinks

The Game may include links or features operated by third parties. gFaUmNe has no control over the way in which such third parties collect and protect personal information. Any information that you provide or that is collected by a third party is provided directly to that third party and is subject to that third party’s terms of use and policies, which we recommend that you read carefully before accessing or using a third-party service.

The Game or the Websites may incorporate links to third parties’ sites or resources on the Internet for your information. By clicking on such links, you leave the Game or the Websites. Any personal information you submit through these sites is subject to such third parties’ privacy policy. We do not exercise any control on the operation of any third parties’ websites or applications.

7. GOOGLE Analytics

We may share information with vendors and other parties for analytics related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information.

The Websites use Google Analytics and might collect information about you during navigation. Google Analytics uses "cookies", which are text files placed on visitors' computers, to help us analyze how you use our Websites. The information generated by such service may include: which pages were viewed and at what approximate date; the approximate location (country) of the visitor.

These analytic data are pre-aggregated by Google, and gFaUmNe do not have access to your personal information.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

8. RIGHTS AND INFORMATION

In certain circumstances and in accordance with EU/EEA and other applicable privacy laws, you may have the right to:

• Request access to the personal information that we have obtained about you.
• Ask that we delete or remove personal information in certain circumstances. There are certain exceptions under which we may refuse a deletion request, such as when personal information is required for legal compliance or in connection with claims.
• Object to our processing of your personal information. However, please note that your unique identifier is required to provide you with the services and subsequently for the purpose of demonstrating your consent.
• Ask us to stop using your personal information (please note that we must sometimes use your information in order to enable you to use the services).
• Have your personal information transferred to another organization (when technically possible).
• File a complaint with a data protection supervisory authority.

Please note that applicable laws may provide for certain exceptions to these rights in certain circumstances. If you have any questions about this policy or about the exercise of any of the above rights, you may contact us at [email protected]

gFaUmNe Inc. 6797 rue Jean Lecompte, Montreal H1N 1G7, Quebec, Canada. c/o Data Protection Officer

Latest update: 2020-04-27