Last Modified 24 May 2018
For purposes of data protection laws, Twisted Bamboo LLC, PO Box 84, San Francisco, CA 94104-9991, is the “data controller” of your information.
Acceptance and Consent:
Information Collection and Use:
Our primary goals in collecting and using information are to provide and improve the Service, to administer and assist you in administering your Account on the Service, and to provide you with a better experience with the Service. We store and process information in the United States. Please note that we need certain types of information so that we can provide the Service to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use the Service.
Information We Collect From You
Twisted Bamboo collects information about you through the means discussed below when we provide the Service.
Use of Account
We may collect your information, including your email address, in connection with your creation of an Account. You can register for an Account via a Twisted Bamboo application. Certain of your information, such as your username and other information, will always be publicly visible by other users of the Forums, including when such users view your Account profile page. Your email address will not be publicly visible unless you choose to make it visible in your Account profile page. When you register for an Account or later access your Account, you will able to adjust settings and preferences within your Account to choose whether to share and make publicly visible other pieces of your information, and the Service will display your information based on the settings and preferences you choose. We encourage you to consider carefully what information to share as part of your Account profile and elsewhere in the Service, and we recommend that you guard your anonymity and sensitive information and not use your real name as your username, as that may allow other users of the Service to identify you. Any information you choose to share should reflect how much you want other users of the Service to know about you. You can review and revise your Account profile information at any time.
We also request and collect your information when you administer or personalize your Account after registration or otherwise interact with the Service. For example, we collect your information both when you enter promotions on or in connection with the Service as well as in connection with your transactions (such as, but not limited to, donations or the purchase of products) through the Service or with Twisted Bamboo’s advertisers. Such transaction-related information includes payment information, such as information regarding your account with an online payment service provider, and information about your use of products and services offered by our advertisers.
Use of Applications
When you launch any of our applications, we collect information regarding your device type, operating system and version, carrier provider, IP address, Media Access Control (MAC) address, International Equipment Mobile ID (IMEI), whether you are using a point package, the game version, the device’s geo-location, language settings, and unique device ID. In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your Account profile information to enable us to move your information to a new device at your request. In addition, it may be used to link a character with which you play our games to your username on the Forums. When you play our games, we also collect information about your play and interaction with other users and the Service.
We may collect Your Information, such as your name or email address, from third party websites or other sources from which you download or access Twisted Bamboo applications, services or products that also make up part of the Service.
We use your information to provide the Service, to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and evaluate how the Service is used. We also use your information to serve you specifically, for instance, by delivering products or advertisements to you according to your preferences or restrictions. We also use your information to contact you with communications such as Twisted Bamboo newsletters, marketing or promotional materials and other information that may be of interest to you.
SMS Notifications & Push Notifications
We receive and store the information you provide, including your telephone number, when you sign up to have SMS notifications sent directly to your mobile device. These messages notify you of in-game activity and may allow you to play the game from your phone. With your consent we may send push notifications to your mobile device to provide game updates and other relevant messages.
You may be able to take part in certain activities in our applications that give you the opportunity to communicate or share information with Twisted Bamboo and other users of our Service. These include: (a) participating in player forums and message boards, (b) posting comments to other users’ profiles, (c) sending private messages or invitations to other users, (d) chat with other users, and (e) posting photos.
We may record and store archives of these communications. You acknowledge and consent to the recording and storage of such communications.
Log Data, Cookies and Web Beacons
We may feature advertisements served by third party advertising companies which deliver cookies to your computer or device so the advertisements you see can be tracked. These advertisers may use information about your visits to our Service in order to provide advertisements about goods and services of interest to you.
You can instruct your web browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If your browser is set to refuse all cookies, however, some features of the Services may not function properly.
We and third party advertising companies may collect information using Web beacons. Web beacons or “gifs”, are electronic images that may be used on our Site, in our Service or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon. Advertisers may use web beacons in connection with our Service in order to collect and use data regarding advertisement performance and your interests for the purpose of delivering relevant advertising to you.
Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.
We may use third-party web analytics services (such as those of Google Analytics and Amplitude) on our Site to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
Legal Bases for Use of Your Information
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your “personal data” (as defined in such applicable laws). To the extent those laws apply, our legal grounds are as follows:
· To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to allow you to play our games.
· Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
· Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes: operating our business and the Service; providing security for our websites, products, software, or applications; marketing; receiving payments; preventing fraud; and knowing the customer to whom we are providing the Service.
· Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations (such as our obligation to share data with tax authorities).
Sharing Your Information
We share your information with third parties with whom we have a business relationship such as advertisers, ad networks and analytics providers. The information shared with these third parties may be used for industry analysis, ad targeting, tracking ad conversions or demographic profiling, or other purposes related to providing the Services to you.
We may employ third party companies and individuals to facilitate the Service, to provide the Service on our behalf, or to assist us in analyzing how the Service is used. These third parties have access to your information to perform these tasks on our behalf and we use good faith efforts to obtain their commitment not to use your information for any other purpose. We may also provide your information to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you.
We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Twisted Bamboo or any third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.
The foregoing applies to personally identifiable information, not aggregated or anonymous information. We may share aggregated or anonymous information about you and other users with advertisers, publishers, business partners, sponsors, and other third parties, in which case such information may be disclosed and used for a broad range of commercial purposes without limitation.
The Service may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Service, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Third parties, whose products or services are accessible or advertised via the Service, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics and others) to serve tailored ads to you on the Service, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Service. We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.
Please note that if you exercise the opt out choices above, you will still see advertising when you use the Service, but it will not be tailored to you based on your online behavior over time.
If you use one of our applications and connect to your Facebook account within such application, you will be providing us with basic account information i.e., user ID, name, email, gender, birthday, current city, profile picture URL and the user IDs of your friends who have also connected with our applications. In addition, we will cache data we receive from the Facebook APIs to improve our user experience. If you want us to delete the data we receive from Facebook about you, please contact us at support@TwistedBambooLLC.com.
We may display an “offer wall” in our applications that is hosted by an offer wall provider. The offer wall allows third party advertisers to provide virtual currency to users 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 are not offers made by Twisted Bamboo. These offers may be displayed to you based on certain technical information, such as your geographic area or anonymous demographic information. After clicking on one of these advertisements, you will no longer be on a Service hosted by Twisted Bamboo. To properly credit user accounts and to prevent fraud, a unique identifier and other information will be shared with the offer wall provider.
Invite a Friend:
You may decide to provide us with another party’s email address to allow us to contact and invite that party to visit or join the Service or so that Twisted Bamboo may facilitate your communication with such other party through methods of communication enabled by the Service (such as when you upload an address book). Such email addresses will be used only for the purpose of sending email communications to the addressee.
Twisted Bamboo may at times offer you the ability to post content to a blog, message board, chat room or within Twisted Bamboo’ applications or other forums (“Forums”). In order to do so, you may be required to provide your information. You should be aware that any visitor to the Forum may read your postings on the Forum. Furthermore, any information that you may post to a Forum, including your username or other Account profile information, will be disclosed and available to all users and viewers of that Forum, and will therefore no longer be private. Twisted Bamboo cannot guarantee the security of such information that is disclosed or communicated online in public areas such as the Forums, and you provide such information at your own risk. Twisted Bamboo does not author, edit, endorse, or monitor any Forum. You acknowledge and agree that Twisted Bamboo has no responsibility for the accuracy or availability of information provided on any Forum. Twisted Bamboo reserves the right at any time, in its sole discretion, to remove any content that a user may post on any Forum and restrict their access to any Forum.
EEA Data Subject Rights
Residents of the European Economic Area (“EEA”), can exercise certain data subject rights available to them under applicable data protection laws. Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. If these rights apply to you, they may permit you to request that we:
For more information on how to exercise these rights, please contact us using the information in the “Contacting Us” section below. If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
Retention of Your Information
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
Twisted Bamboo 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 Service 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 Account or any of your information will be protected against, loss, misuse, or alteration by third parties.
Twisted Bamboo reserves the right to transfer your information in connection with a change or transfer of Twisted Bamboo’s ownership or a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy, including in the course of diligence.
The information discussed in this Policy is collected and controlled by Twisted Bamboo in the United States. If you are located outside the United States and choose to provide information to us, you agree that such information will be processed in the United States for the purposes described herein. As described above, Twisted Bamboo also may subcontract the processing of your data to, or otherwise share your data with, Twisted Bamboo subsidiaries, service providers, and business partners in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. You expressly consent to such transfer and processing.
Third Party Links:
Opt-In and Opt-Out Policy:
You may “opt-out” of receiving certain types of communications at any time by contacting Twisted Bamboo at support@TwistedBambooLLC.com.
Notice to California Residents:
Under California’s “Shine the Light” law, California residents who provide personal information (as defined by applicable California law) in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2013 will receive information regarding 2012 sharing activities). To obtain this information please send an email message to support@TwistedBambooLLC.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Our Policy Regarding Children:
The Service is not directed to children under the age of 13. We do not knowingly collect or solicit personally identifiable information from children under 13. If you are under 13, please do not attempt to register for an Account on the Service or send any information about yourself to Twisted Bamboo. If we become aware that a child under 13 has provided us with personal information (as defined by the United States Children’s Online Privacy Protection Act), we will delete such information from our files.
We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.