Privacy Policy Table of Contents 1. Introduction 2. Information We Collect and How We Collect It 3. How We Use the Information We Collect 4. How We Share Your Information 5. How to Access, Update and Manage Your Information 6. California Online Privacy Protection Act Notice 7. Privacy Policies of Third Party Services and Advertisers 8. Our Policies Concerning Children 9. International Operations and Transfers Out of Switzerland and the EEA 10. How Long We Keep Your Information 11. Security of Your Information 12. Changes to Our Privacy Policy 13. Contact Us 1 Introduction Rolltower Studios, Inc develops and publishes social games for the web and mobile devices. “Rolltower,” or “we” or “us” refers to Rolltower Studios Inc. in this Privacy Policy. This Privacy Policy applies whenever you play our games or otherwise access any of our other products, services, content, rolltower.com and/or the other domains provided by Rolltower, 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 Rolltower to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play Rolltower’s games or use Rolltower’s Services. 2 Information We Collect and How We Collect It Information About You That We Get From Social Networks (like Facebook) If you play Rolltower’s games or access any of our other Services on a social network like Facebook, Rolltower receives certain information about you from the social network automatically. The information we receive depends on the Rolltower game you’re playing, the social network, and your privacy settings and your friends’ privacy settings on that social network. For example, Rolltower may collect and store some or all of the following information provided by the social network: your first and last name; your profile picture or its URL; your social network ID number (like your Facebook ID number), which is linked to publicly-available information like your name and profile photo; the social network ID numbers and other public data for your friends; the login e-mail you provided to that social network when you registered with it; your gender; your birthday and/or age range; any other information that you or the social networks share with Rolltower. If you access our Services from a social network, you should also read that social network’s Terms of Service and Privacy Policy. If you are unclear about what information a social network is sharing with us, please go to the social networks where you play our games to find out more about their privacy settings. Cookies and Automated Information Collection We and service providers acting on our behalf, like Google Analytics, 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; tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively; and local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times. 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 Rolltower 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 Rolltower games on your mobile device, in addition to your device identifiers, we may also collect: the name you have associated with your device; your mobile contacts (as further described below in “Information About Your Contacts”); 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 Rolltower 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 set-up 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 Rolltower 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 Rolltower player ID number that is created by Rolltower and used to identify your profile. Certain information in your Rolltower profile will be publicly accessible on Rolltower’s websites that offer direct access to Rolltower games, including: The Rolltower player ID; Your first and last names; and Your player profile picture. Your Rolltower player ID number used to identify your account and player profile will appear in the URL of your profile page. It will only allow access to information you make public in your settings. Information About Your Contacts We may give you the ability to import your address book contacts or manually enter them so that you can locate your contacts on Rolltower and invite them to join you in our games or other aspects of our 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 Rolltower users importing or entering their contacts. We use and may store this contact information to help you and your contacts connect through our Services. If you want to remove your contacts stored by us, follow the instructions provided in the game to request that we remove them from our systems. If you need to enter a password to allow us to access your address book, we will not store that password. Information You Generate Using Our Communications Features You may be able to take part in certain activities on our Service that let you communicate or share information not just with Rolltower, but also with other Rolltower 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 Rolltower's servers to make use of them to protect the safety and well-being of our players and Rolltower’s rights and property in connection with the 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 on Rolltower.com, 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. Rolltower does not collect or store your financial information, like credit card numbers. However, Rolltower’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. Rolltower 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 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 Rolltower 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. Information You Give Us For Text Messaging Services We receive and store the information you provide, including your mobile telephone number, when you choose to sign up to receive SMS messages. Game Toolbars or Game Bars You may have installed a Rolltower-branded toolbar (the "Toolbar") when playing various games. The Toolbar is based on technology provided by Conduit, a third party, whose privacy policy is available here. The Toolbar will automatically update on your browser with improvements. The Toolbar itself may collect information like your social network ID. Some Toolbar features may let you provide personal information (for example, Contact form, Tell-a-friend). We may also keep statistics regarding how players use the toolbar on an aggregated basis. For more info on the Toolbar and instructions for uninstalling it go here. 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 keep your information secure, please see Security of Your Information. back to top 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 Rolltower 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 Rolltower's 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 e-mail address to Rolltower, 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 “crops ready” as well as tell you about gift and neighbor 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 e-mail messages and promotional SMS messages (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. back to top 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 San Francisco) and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, and advertising, and other business purposes. In addition, we will share your information (which may include personal information) with third parties (in other words, parties other than Rolltower) 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 Rolltower Players The Service supports and often encourages you to interact with other players. In most Rolltower 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 Rolltower games, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity, 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 Rolltower Poker, any other player may see your game profile if you are playing at the same table. In certain cases, your profile photo, can reveal your social network ID or Rolltower player ID, and access to a social network ID or Rolltower player ID may allow others to view the public information associated with your related social network profile or Rolltower account. Other players may also be able to send you game requests or even friend requests through the related social network’s or Rolltower’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 San Francisco); 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 Rolltower or the social network through which you are playing Rolltower’s 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. Safety, Security and Compliance with Law Your information, and the contents of all of your online communications in our Services and between You and Rolltower 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 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 Rolltower and other applicable third parties, including to enforce our Terms of Service. Offer Walls Rolltower games or their purchase pages may display an “offer wall” that is hosted by an offer wall provider. The offer wall allows third party advertisers to provide virtual currency to players in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These offers are not made by Rolltower. These offers may be shown to you based on certain technical information, like your geographic area or de-identified demographic information. After clicking on one of these offers, you will no longer be on a site hosted by Rolltower or the social network through which you are playing Rolltower’s games. To properly credit player accounts and to prevent fraud, a unique identifier, in some cases your social network ID or Rolltower player ID, will be shared with the offer wall provider. 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 Rolltower undergoes a business transition, like a merger, acquisition by another company, or sale of all or part its assets (like selling a game), we may 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. back to top 5 How to Access, Update and Manage Your Information Information We Receive From a Social Network Where You Play Our Games or From Your Mobile Device To manage the information Rolltower receives about you from a social network, like Facebook, where you play our games, you will need to follow the instructions at that site for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here. To review and update information associated with your Rolltower 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 Rolltower receives your information from a social network or your mobile device, that information is stored and used by Rolltower in accordance with this Privacy Policy. You may access and update that information as described below. Accessing and Updating Your Information Held by Rolltower If you want to review, delete, or change the information Rolltower has about you or have additional questions, e-mail us at support@Rolltower.com We will respond to your request within thirty days. Stopping Use of Your Information If you no longer want Rolltower to make active use of your information, you may send an e-mail to support@Rolltower.com Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail (for example, your Facebook user ID). We will respond to your request within thirty days. 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 Promotional Emails from Rolltower If you want to stop receiving promotional e-mails from Rolltower, click on the "unsubscribe" link in any promotional email from Rolltower or visit the e-mail preference page. 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 You can opt out of receiving SMS messages (for example, text messages) by texting back STOP to the number we send the text from for that particular SMS message program. In some cases a preferences management page will also be available. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out. When you install our apps on your mobile device you can choose to receive 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. Note that if you opt-out of our Promotional Communications or other forms of communication, we may still e-mail or communicate with you from time to time if we need to provide you with information about the Service or if we need to request information from you with respect to a transaction initiated by you or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy or our Terms of Service. 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: Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising; and Your Online Choices UK website for EU-based advertising. These opt-out tools are provided by third parties, not Rolltower. Rolltower 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 Rolltower. Rolltower 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 Rolltower’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. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel. If you disable cookies, you may lose some of the features and functionality of our Services because Rolltower cookies are necessary to track and enhance your game activities. back to top 6 California Online Privacy Protection Act Notice At this time, there is no general agreement on how companies like Rolltower should interpret Do Not Track signals. Rolltower does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device. You can learn more about Do Not Track here. back to top 7 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 Rolltower 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. back to top 8 Our Policies Concerning Children Our websites and games are not for children under the age of 13 and we do not knowingly collect any personal information from children under 13. Children under 13 should not use our websites or games at any time. If we learn that we have inadvertently gathered personal information from a child under 13, we will take reasonable measures to promptly remove that information from our records. back to top 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. back to top 10 Security of Your Information We implement appropriate security measures to protect the security of your information both online and offline, and we are committed to the protection of customer information. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. If you have an account registered directly with Rolltower, your profile information is protected by the password you use to access your Rolltower account. It is important that you protect and maintain your Rolltower account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your Rolltower account, the Service allows you to request that instructions be sent to you that explain how to reset your password. If you access our Services through a social network and your social network account is hacked, this may lead to someone playing your Rolltower games without your permission. So, be careful to keep your social network account information, including your social network account password, secure as well. We urge you to log out of your Rolltower account and any social network account you have used to access our Services after you use it. When you sign into your Rolltower account or enter payment information, we or our third party payment processor use secure socket layer technology ("SSL") to encrypt the transmission of that information. While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. Although we strive to protect your personal information, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, 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 websites, please contact us at support@Rolltower.com (link sends e-mail). back to top 11 Changes to Our Privacy Policy If we decide to make material changes to our Privacy Policy, we will tell you and other players by placing a notice on Rolltower.com or its equivalent in-game, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other Rolltower websites. You should periodically check www.Rolltower.com and this privacy page for updates. back to top 12 Contact Us If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to support@Rolltower.com. Rolltower Studios Inc. support@rolltower.com This document was last updated on May 6 2015