COLLECTION OF PERSONAL INFORMATION
Hothead generally collects your personal information through:
- your access to and use of Hothead software applications for mobile devices or other devices (“Hothead Applications”),
- your access to and use of Hothead’s website (www.hotheadgames.com) (the “Website”),
- any dealings that you have with Hothead (for example, by contacting Hothead for any purpose), and
- third-party organizations, including those that distribute Hothead Applications or who process payments for in-app purchases within the Hothead Applications (as of the date above: Apple, Google and Amazon), our advertising partners (including advertising networks, many of which are specifically listed below), and credential management partners, such as Facebook. The type of information that we collect in these circumstances will vary depending on the third party and the type of Hothead Application, but will generally include contact and demographic information such as your name and email address, age, user ID, account or registration information and location information. When you use a social media credential to log in, additional information we receive may include your public profile (including photo) and friends list.
In certain circumstances, third parties may collect your personal information in connection with your access to and use of the Hothead Applications or the Website. This includes our advertising partners, such as:
- Vungle and certain of its advertising-related partners, each of whom may use tracking technology to collect, use and share ad-related data (for example, unique device identifiers, information about ads viewed or clicked, and streaming data).
We also have several other advertising partners, which may change from time to time and include AdColony, AdMob, AppLovin, Chartboost, Crashlytics, Flurry, Fyber, Keywords International Limited, Helpshift, HyprMX, Kiip, Kochava, MoPub, Singular, Swrve and Tapjoy. These partners may collect, use and disclose personal information as set out in their respective privacy policies.
Personal information is any information that relates to an identified or identifiable natural person. This might include your name, address, email address or phone number, and sign-in information for third-party social networking services. The personal information that Hothead collects will vary depending on the type of products or services that you are using, including the Website or Hothead Applications, and how you access and use those products or services, but may include your name, contact information (such as email address, mailing address, fax number, and telephone number), demographic information (such as gender, age, and occupation), your device’s IP address, unique device identifier, MAC address, or other transactional or identifier information regarding your device or systems, geolocation information, “cookies”, social media information, and personal preferences. This information may also include the length of time you used or played any Hothead Applications, the features of Hothead Applications that you used, your game progress, and other game-related statistics.
Hothead may also collect and analyze non-personal information to evaluate how users use the Website or Hothead Applications. Such non-personal information may include general technical information about your computer, device, hardware, or software that you use to access the Website or Hothead Applications, or any of the information described above in circumstances where that information does not relate to an identified or identifiable natural person.
PURPOSE FOR PROCESSING PERSONAL INFORMATION
Hothead may process (for example, collect, use and disclose) information, including personal information, in the following ways:
- to develop, deliver, maintain and improve Hothead Applications, the Website and other Hothead products and services and to better tailor them to meet the needs of Hothead’s users, customers and potential customers (including for analytics purposes);
- to develop, deliver, maintain and improve Hothead’s marketing and promotional efforts and manage its relationship with you;
- for third parties to provide Hothead and you with their products and services (including in relation to advertising), including to make ad targeting decisions, conduct audience segmentation and targeting in connection with online behavioral advertising, provide monetization services to their customers, assist their customers with maintaining their services, improving their services, and analysing the marketplace for their services as well as for the performance of their services, improving their services, and researching and developing new services, for fraud prevention, bot detection, quality rating, analytics, enhancements. These include:
- optimization, viewability, geolocation services, ad security, ad verification services, and service misuse prevention;
- to communicate with you in connection with Hothead Applications or the Website;
- to assist law enforcement agencies with the investigation of actual or potential fraud or other offences;
- for any other purpose in connection with Hothead’s or a third party’s legitimate business interests (including in connection with actual or potential the sale, reorganization, or management of all or part of its business or operations);
- to establish or exercise legal rights or defend against legal claims; and
- as otherwise required or permitted by law.
Any of the foregoing may involve us combining the personal information we collect with personal information collected by third parties, such as our advertising partners, business partners and services providers.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
RETENTION OF PERSONAL INFORMATION
Hothead will retain personal information:
- in relation to a Hothead Application, until we permanently discontinue the game (we assume you want to be able to restore your gameplay at any time, so we only delete information where we are discontinuing the game and have decided to never restore it); and
DISCLOSURE OF PERSONAL INFORMATION
Hothead may disclose your personal information to the following organizations or types of organizations:
- third party service providers and Hothead’s affiliated entities who carry out work on behalf of, or provide products and services to, Hothead,
- law enforcement agencies,
- legal, financial, insurance, and other advisors, and
- as otherwise required or permitted by law.
Hothead will not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required or permitted by law. Hothead acts as the controller in relation to your personal information, but there may be some circumstances in which a third party recipient of that information may also act as the controller of that information.
Transfer of personal data outside of the EU
In certain cases where your personal information has been collected in the EU, that personal data may be transferred outside of the EU. Hothead (or its partners) will take steps to ensure such transfer is carried out in accordance with applicable data protection laws. This includes that any third party recipient outside of the EU will ensure an adequate level of protection, for example, by adhering to the EU-US or Switzerland-US Privacy Shield or entering into the EU standard contractual clauses with the party that transferred that information.
In addition, you may have the right in certain circumstances under privacy laws to request from Hothead:
- access to,
- rectification or erasure of,
- restrictions in relation to the processing of (including in relation to direct marketing), and
- data portability in relation to,
the personal information that we hold about you.
Please contact Hothead’s privacy officer in order to make such a request.
CALIFORNIA PRIVACY RIGHTS
Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year.
PRIVACY OF CHILDREN
Hothead does not knowingly collect personal information from children under 16 without appropriate parental notice and consent. If you are under 16, please do not attempt to use the Hothead Applications or the Website or send any information about yourself to Hothead, including your name, address, telephone number, or email address. No one under age 16 may provide any personal information to Hothead. In the event that Hothead learns that it has collected personal information from a child under age 16 without verification of parental consent, Hothead will delete that information as quickly as possible. If you believe that Hothead might have any information from or about a child under 16, please contact Hothead’s privacy officer.
Hothead Games Inc.
Attention: Director of Technology (Privacy Officer)
Address: 1555 W Pender St., Vancouver, BC, Canada V6G 2T1
Last updated: September 10, 2018