PRIVACY POLICY

Effective Date: 07.15.2022

  1. Introduction

Duole Games(collectively “we”, “our”, or “us”) are committed to protecting your privacy and take the protection of your personal data very seriously. This privacy policy (“Privacy Policy”) explains how we collect, use and share the personal data that you provide to us and what we collect when you use any of our websites (each, a “Website”) mobile applications (each, an “App”), and our chat service, forums, message boards, email service, messaging services, virtual communities, virtual assets, polls, surveys, and similar services (each, a “Community Feature”). The Website, Apps and Community Features are collectively referred to as the “Services.”

Please note that the scope of this Policy is limited to information and data collected or received by we through your use of the Services. we is not responsible for the actions of individuals with no relationship to we or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.

If you do not want we to collect, store, use, or share your information in the ways described in this Policy, you should not use our Services.

  1. Information and Data We Collect from You and How We Collect It

When you use our Services, you may give us your contact information directly on our website, generally your name and email address.

Registration Information:

We may also offer you the option to complete a user profile that is visible to other we users (“Account”).If you create an Account, you may provide us you name, a username, e-mail address, a password and other information that helps us confirm that it is you accessing your Account. We may do this through in-game dialog boxes, which you may choose to skip. If you sign into the Services with Facebook Connect we will collect information that is visible via your Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook friends. Your Account may be used to publicly identify you as part of social features of the Services, which may include user-to-user interaction, chat or messaging functionality, public leaderboards, head-to-head competition, and other similar features. The we username will be public and will be shown to other users, but will only permit access to information that is considered public or that you have designated as public in your user profile settings.

We may also offer you the ability to import your contacts or manually enter e-mail addresses so that you can locate your contacts and invite your contacts to join you in the Services. We will store those contacts for purposes of helping you and your contacts make connections through our Services.

Payment Information

When you order any good or service through the Services, including any virtual currency or virtual good, our payment processing service provider will collect your name, phone number, e-mail address, mailing address, billing address, and complete credit card information that enables them to receive your payment.  Our payment processing service provider may also retain this information to enable you to purchase additional items through our Services without having to re-enter it each time. Please note that purchases from third parties may also be subject to additional policies

Information Collected by Customer Support

When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your gameplay or activity on the Services, and your user-name or ID number. We will also store the correspondence and any information contained within.

Technical and Usage Information

We automatically collect information about you when you use the Services, such as:

a) Device Information: If you access the Services through a mobile device, we may be able to identify the general location of your mobile device (not precise geolocation data), your mobile device’s brand, model, operating system, resolution, screen size, system version, Bluetooth settings, internet connection, random-access memory (“RAM”), the application you have installed, the applications you have running in the background, mobile device’s advertising ID, other unique identifiers and other information related to device setting.

b) Cookies & Similar Tracking Information: We use cookies and similar tracking technologies to collect information about your interactions with our Services. The information we collect includes, but is not limited to, account activation time, content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, URLs you have visited, notifications that have appeared on your mobile device, your Internet Protocol (“IP”) address, your mobile country code, and your user ID.

c) Content Sharing: When you choose to share content with us, we automatically collect information about your Wi-Fi connection, and call information. You may be able to limit the amount of information collected from your device (e.g., computer, phone, or tablet) with us by adjusting your device or browser settings. However, by preventing us from collecting information from you, we may not be able to provide some functions on our Services.

  1.  How We Use Your Information

we's primary goals in using your information are to create your account, provide Services to you, troubleshoot, improve and optimize our Services, contact you, conduct research and create reports for internal use.  We use information collected through our Service for purposes described in this Policy or disclosed to you in connection with our Service. For example, we may use your information to:

  • Create accounts and allow users to use our Services;
  • Identify and suggest connections with other we users;
  • Operate and improve our Services;
  • Understand you and your preferences to enhance your experience and enjoyment using our Services;
  • Respond to your comments and questions and provide customer service;
  • Provide and deliver products and services you request;
  • Deliver advertising and marketing and promotional information to you;
  • Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • Communicate with you about promotions, contests, rewards, upcoming events, and other news about products and services offered by we and our selected partners;
  • Conduct and administer contests promoted by we;
  • Enable you to communicate with other users; and
  • Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services.
  1. Use of Your Information by Others

Third Party Services. We may provide your information to third party companies to perform certain services, including but not limited to hosting services, payment processing, analytics, customer service and to assist us in our marketing efforts. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information as required by applicable data protection laws.

Advertising. To the extent we display advertising in our Services, we may allow advertising networks of our affiliates and partner networks to collect information about your mobile device to enable them to serve targeted ads to you. Such mobile device data includes the following:

  • Device make, model and operating system;
  • Device properties related to screen size & orientation, audio volume and battery;
  • Carrier;
  • Operating system;
  • Name and properties of mobile application through which a consumer interacts with the Services;
  • Country, time zone and locale settings (country and preferred language);
  • Network connection type and speed;
  • IP Address;
  • Internet browser user-agent used to access the Services; and
  • Advertising ID (IDFA on iOS devices and GAID on Android devices).

A list of partners and links to their privacy policies can be found here:

Partner Link to Privacy Policy
Facebook https://www.facebook.com/privacy/policy/
Admob https://policies.google.com/privacy
Firebase https://policies.google.com/privacy
Appsflyer https://www.appsflyer.com/legal/privacy-policy/
Flurry https://legal.yahoo.com/us/en/yahoo/privacy/index.html
DT https://www.digitalturbine.com/privacy-policy/
chartboost https://support.chartboost.com/en/legal/privacy-policy
mintegral https://www.mintegral.com/en/privacy/
Unity https://unity.com/legal/privacy-policy
Applovin https://www.applovin.com/privacy/
inmobi https://www.inmobi.com/privacy-policy
liftoff https://liftoff.io/zh-hans/privacy-policy/
ironsource https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
pubmatic https://pubmatic.com/legal/privacy-policy/
smaato https://www.smaato.com/privacy/

The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices. We encourage you to check those privacy policies to learn more about their practices.

You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program.  If you wish to opt-out of interest based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice.  AppChoices is available at the links below:

DAA AppChoices iOS

DAA AppChoices Android

DAA AppChoices Amazon

You may also limit data collection by third parties by using your mobile device settings.  Please note that electing to opt-out will not stop advertising from appearing in your browser or applications.  It may make the ads you see less relevant to your interests.  Additionally, please not that if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choices.

  1. How We May Disclose Your Information to Third Parties

we does not share your personal information except as approved by you or as described in this Policy.

We may share information we collect or derive with third parties for the following purposes:

  • With service providers that perform services on our behalf, including the ones referenced above under “Third Party Services”;
  • With our affiliates;
  • For analytics and research purposes;
  • When we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including law enforcement or legal process purposes;
  • To satisfy any applicable laws or regulations;
  • When we believe in our sole discretion that our Services are 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;
  • To protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim;
  • As part of a business transfer such as a merger, acquisition, or at bankruptcy;
  • We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties; and
  • We may use analytics services provided by third parties, including Google Analytics.  These service providers may use cookies to collect information about your online activities across this and other sites over time for non-advertising purposes.  To learn more about how Google analytics collects and processes data and the choices Google may offer to control these activities, you may visit http://www.google.com/intl/en/policies/privacy/partners/. 
  1. Data Deletion

For any of the personal information described above, you can request that we delete your personal information at any time.

To exercise your right to know and right to deletion, please submit a request by emailing [email protected].  We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity. Upon verification of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless retaining the information is necessary for us or our service providers to complete the transaction with you, detect security incidents or fraud, fixing errors, exercise free speech or another right provided by law, comply with legal obligations, or other internal and lawful uses.

    1. Specific Provisions for EU Individuals

    Accessing and Correcting Your Personal Information.  At any time, you can contact us at [email protected] and request to access the personal data that we holds about you. we may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, then please provide we with the necessary information to correct it.

    Withdrawing Your Consent. Contact us at [email protected] if you would like to withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.

    Erasing or Restricting Access to Your Information.  You can contact us at [email protected] and request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.

    Transferring your Personal Data (Otherwise known as Your Right to Data Portability).  You have the right to receive your personal data that you have provided us in a structured, commonly used and machine-readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.

    Right to Make Complaint: if you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

    If you have any concerns about the way we process your personal data, you are welcome to contact our data protection officer at [email protected]. We will look into your request and make good faith efforts to resolve any concern you may have.

    1. Security Safeguards

    we takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties.  Although we make good faith efforts to store the information collected on the Services in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems.  Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.  We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, we cannot guarantee its absolute security.

    1. Data Retention

    we retains your personal data for as long as needed to provide you Services, unless we are required by law to delete or if we accepts your request to delete the information. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

    1. Our Policy Regarding Children

    We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Services.  If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data.  In the event that we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible.  If you believe that we might have any information from or about a child under the age of 16, please contact us.

    1. Cookies and Other Tracking Technologies

    1) What Are Cookies

    Cookies are small text files containing small amounts of information which are downloaded and may be stored on any of your internet enabled devices e.g. your computer, smartphone or tablet - like a memory for a web page. This means we automatically collect and store the following information about your visit:

    Ÿ the internet domain and IP address from where you access the Service;

    Ÿ the type of browser software and operating system used to access the Service;

    Ÿ the date and time you access the Service;

    Ÿ if you linked to the Service from another website, the address of that website; andthe pages you enter, visit and exit from the Service.

    2) How We Use Cookies

    We use the following cookies: Login related cookies;We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.

    Site preferences cookies to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

    3) Third-party Analytic Service Provider

    In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site. These cookies are likely to be analytical/performance cookies or targeting cookies. You should refer to the third parties’ own cookie and privacy policies for information about how they may use your information.In particular, we use Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes, and to help improve the overall experience of our Service.We use Google Analytics, a third-party web analysis service provided by Google Inc, which uses “performance cookies” and “targeting cookies” to analyze how you use the Website. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. However, this website uses Google Analytics with the feature of ' IP Anonymization ', which means that Google will truncate/anonymize the last octet of the IP address for Member States of the European Union. On behalf of us, Google will use the information collected for the purpose of evaluating your use of our Website, compiling reports on website activity and providing other services relating to website activity and internet usage to us. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser as described above. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB# . You may disable the use of Google Analytics by using the link disable Google Analytics. This link creates an opt-out cookie which prevents the further processing of your data. For more information about Google Analytics cookies, please see Google's help pages and privacy policy. If you do not accept the use of these cookies, we cannot guarantee how our Website will perform for you.You can find more information about the Google Analytics cookies

    here:https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie usage .

    Besides Google Analytics, we also use Facebook Insight to help us know better our website page performance, like demographic data about our audience. With Insight, we can use understand how people are engaging with our page, view metrics about our page's performance. Please note that we do not merge personally-identifiable information with the non-personally identifiable information collected through any third-party analytics service.

    You can learn more on how Facebook to collect and use your cookies from

    https://www.facebook.com/policies/cookies/

    4) Disabling Cookies

    You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore.it is recommended that you do not disable cookies.

    For more information about how to do this, please see http://www.allaboutcookies.org/manage-cookies/clear-cookies-installed.html , or follow the 'Help' option in your internet browser for more details.

    To block Google Analytics cookies specifically, you can install the “Google Analytics Opt-out Browser Add-on” provided by Google. If you share the use of a computer, accepting or rejecting the use of cookies may affect all users of that computer.

    5) More Information

    Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.However if you are still looking for more information, you can contact us.

    1. Transfer of Personal Data Outside Your Country

    We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal data, as described in this Policy.

    1. Lawful Basis for Processing

    On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide the Services to you.  We may also process your personal data to respond to your inquiries concerning our products and services.

    On other occasions, we process your personal data where required by law.  We may also process your personal data if necessary to protect your interests or the interests of a third party.

    Additionally, we process your personal data when necessary to do so for fraud prevention, improving our network and services, and marketing our services to advertisers and publishers; where these interests are not overridden by your data protection rights. 

    If the processing of personal data is necessary and there is no other lawful basis for such processing, we will generally ensure that consent has been obtained from you.  You have the right to withdraw your consent to processing of personal data at any time.

    For questions about data processing, please contact our Data Protection Officer at [email protected]

    1. Specific Provisions for California Consumers

    These additional provisions for California consumers apply only to individuals who reside in California.  The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires “businesses” collecting or disclosing personal information to provide notice and a means to exercise those rights.

    Categories of personal information collected in the preceding 12 months:

    • See Section 2 above (Information and Data We Collect From You and How We Collect It)

    Business purpose for collection

    • See Section 3 above (How We Use Your Information)

    Third parties with whom we may share your information

    • See Section 4 above (Use of Your Information by Others)

    Right to Know and Right to Delete

    For any of the personal information described above, you can request to know what personal information we collected, disclosed, used and sold, and request that we delete your personal information at any time.

    To exercise your right to know and right to deletion, please submit a request by:

    Emailing [email protected] with the subject line “California Rights Request.”  We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.

    Upon verification of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless retaining the information is necessary for us or our service providers to complete the transaction with you, detect security incidents or fraud, fixing errors, exercise free speech or another right provided by law, comply with legal obligations, or other internal and lawful uses.

    Right to Opt Out of Sale

    CCPA gives you a right to direct a business that sells your personal information to stop selling  your personal information and to refrain from doing so in the future. We do not sell any of your personal information and will require our service providers not to sell your personal information.

    You also have the right not to be discriminated against for exercising any of the rights listed above.

    If you are a California resident seeking to exercise your rights under the CCPA or have any questions or concerns, please email us at [email protected].  In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

    We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

    1. Changes to This Policy

    We may update this Policy to reflect changes to our data and information privacy practices. If we make any material changes we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Please note that if we needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.

    1. Contact Us.

    You can contact us at [email protected].