LAST UPDATED: September 7, 2015
1. OUR COMMITMENT TO PRIVACY
If you are a customer of iPro located in the European Economic Area (EEA), we have certain obligations to you regarding the management and process of your personal information under the Gibraltar Data Protection Act 2004 under which iPro is registered with the Gibraltar Regulatory Authority.
2. APPLICATION AND SCOPE OF THIS POLICY
3. WHY WE COLLECT INFORMATION
We collect information in order to:
Enable us to set up, operate and manage your ringit! account so that you can make full use of our Services;
Verify your location, age and identity when you are using your account;
Comply with relevant regulations regarding your registration;
Enable us to receive questions and comments from you so we can provide technical assistance;
Keep you informed of future events, offers and promotions.
We also collect, use, share, transfer and store information as set forth below.
4. THE INFORMATION WE COLLECT
User Provided Information
You provide certain personally identifiable information (such as your name, email address, PayPal or credit card billing information, contacts you choose to submit, and profile photo) to iPro when choosing to participate in various activities on the Service such as registering for a ringit! account, participating in contests, uploading pictures, posting messages, taking advantage of promotions, responding to surveys, or subscribing to newsletters or other mailing lists.
To provide our Services to you, we collect and use information related to the actual geographic location of your wireless device; we obtain this information from your wireless carrier, certain third-party service providers, or directly from the wireless device you used to register.
Log File Information
When you use our Services, our servers automatically gather and store certain information about your usage. These server logs may include information such as a wireless device identification number and device identifier, web requests, Internet Protocol (“IP”) address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, search terms, ratings, landing pages, pages viewed and the order of those pages, features used in our Services, our wireless application(s), alerts received, advertisements delivered, the amount of time spent on particular screens, the dates and times of your requests, and one or more cookies that may uniquely identify your browser.
Clear GIFs Information
When you use ringit!, we may employ technology such as "clear GIFs" (a.k.a. Web Beacons) which are used to track the online usage patterns of our Users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.
Mobile or Online App Information
When you use our ringit! mobile or Online apps, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device, device state information, default device language, the location of your device, and app usage information.
When you choose to download Software pursuant to our Services, notification software may also be downloaded onto your Access Device. This allows us to send notifications to you about our Services directly to your Access Device, for example to inform you about new features, updates, service communications, offers and promotions. By downloading such Software, you consent to receiving notifications. If you would prefer not to receive these notifications, you will need to opt out by manually uninstalling the notification software from Your Access Device.
For the purposes of prevention or detection of crime as well as responsible gambling, we may supplement the information that You provide to us with information that we receive from third parties or collate by accessing third party sources, including (without limitation) information published on the internet about or by You on social media and social networking sites.
5. HOW WE USE INFORMATION
We use the above information to enable us to set up, operate, and manage your ringit! account, and to provide to you the features and functionality of the app, including but not limited to the following: (a) providing you our products and services, including our games; (b) processing and responding to inquiries; (c) alerting you to new Service features, special events, products and services, or certain third-party products or services in which we think you will be interested; and (d) enforcing the legal terms that govern your use of the Service.
With your consent, we may also use your location information to determine whether (i) you are in a jurisdiction where our Services are lawful, (ii) your wireless device matches your account while you are in the ringit! approved jurisdiction, (iii) which of our Services alerts are relevant to you. We reserve the right to use your anonymous location information for other purposes.
We may use your information to contact you for both marketing and non-marketing or administrative purposes (such as notifying you of major ringit! changes or for customer service purposes).
We use your information to improve the quality and design of ringit! and to create new features, promotions, functionality, and services, such as by storing, tracking, and analyzing User preferences and trends.
Your information may be used in the investigation of suspected unlawful, fraudulent or other improper activity connected with the Services, the reporting of a crime or suspected crime, including money laundering or any fraud; and any other purpose which is necessary for the performance of our contractual obligations to you.
We may store and process your information on our own information technology systems or on systems owned by third parties that may store and process your information on our behalf.
We may anonymize or aggregate your information for business purposes, including for reporting and research. Anonymous and/or aggregated data does not identify you, and we may use and disclose such information without limitation.
6. WHEN WE SHARE INFORMATION
We may share your information with our subsidiaries, affiliated companies, agents, or other businesses or persons for the purpose of processing such information on our behalf, including by using the information to make improvements to the services they provide. We may share your personally identifiable information with third parties for their commercial or marketing use with your consent or as part of a specific program or feature for which you will have the ability to opt-in or opt-out. We may disclose personally identifiable information in response to your requests for customer service. As agreed in our Terms of Service, we may use personal information about you (such as your name and photo) in connection with marketing and publicity purposes. When you participate in a contest, we may publish your username on a list of the contest participants, along with a link to your profile page. We also may share personally identifiable information in other situations with your consent.
iPro reserves the right to disclose personally identifiable information that iPro believes, in good faith, is appropriate or necessary to enforce our Terms of Service, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to a subpoena, legal order, or official request, to protect the security or integrity of our Service, and to protect the rights, property, or safety of iPro, our Users or others. Information also may be shared as described in the Merger, Sale or Bankruptcy section below.
iPro may also share or sell your anonymous location information to third parties.
7. UPDATING YOUR INFORMATION FOR USERS IN THE EEA
We may reject requests for disclosure or deletion of your Information that are unreasonable or extremely impractical.
8. YOUR CHOICES
You may, of course, decline to submit personally identifiable information through ringit!, in which case iPro may not be able to provide certain services to you.
9. DATA SECURITY
To prevent unauthorized access, maintain data accuracy, and to protect personal information about you, we have put in place commercially reasonable physical, electronic, and procedural safeguards that comply with federal regulations. We cannot, however, ensure or warrant the security of any information that we receive on your behalf to operate our Services or that you transmit to us, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If we learn of a security breach we may attempt to notify you electronically so that you can take appropriate protective steps and/or post a notice on our website if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
10. OUR COMMITMENT TO THE PRIVACY OF PERSONS UNDER 18
We do not knowingly collect or maintain personal information from anyone under 18 years of age. If we learn that we have collected the personal information of someone under 18 years of age we will take the appropriate steps to protect this information. If you are a parent or guardian and discover that your child has submitted personal information, you may alert us at: firstname.lastname@example.org
11. THIRD-PARTY ADVERTISERS AND ANALYTICS COMPANIES
12. INTERNATIONAL TRANSFER OF YOUR INFORMATION
Through your continued use of the ringit! Mobile or Online App, you consent to the international transfer of your information.
13. TAX FORMS
In certain circumstances, such as when you win certain amounts through our Web Site contests, we may require you to provide your social security number for tax purposes. Your social security number will otherwise be kept confidential by us, except as required by law.
14. YOUR CALIFORNIA PRIVACY RIGHTS
If you reside in California, you may request certain general information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at the following address: email@example.com
15. IN THE EVENT OF MERGER, SALE, OR BANKRUPTCY
In the event that iPro is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, or other change of control, there may be a disclosure of your personally identifiable information to another entity related to such event, and we may not control how the information is treated, transferred, or used by that entity.