Effective January 1, 2017

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICES.

Introduction

Cleebo Games Inc., its subsidiaries, parent companies, joint ventures and other corporate entities under common ownership and/or any of their agents, consultants, employees, officers and directors (collectively referred to as “Cleebo” or “our” or “we” or “us,”) develops and publishes social games for the web and mobile devices. The Cleebo Social Casino is a social gaming website (the “Website”) intended for players 21 years of age, or those who have reached the age of majority in their jurisdiction. Cleebo does not offer “real money gambling” or an opportunity to win real money or prizes based on the outcome of play. Playing Cleebo Casino does not imply future success at “real money gambling.”

The Privacy Policy is incorporated by reference into our Terms of Use, available here and forms part of the Terms and is in addition to and shall not derogate in any way from the Terms. All capitalized terms not otherwise defined in this Privacy Policy shall have the same meaning as they do in the Terms.

Please read this privacy policy (the “Policy”) carefully before accessing the Services as it provides important information about how we collect, store, use and disclose your information when providing our Services to you or when you access this Website. This policy applies to your access and use of our Services on any platform, including through the Websites or through our mobile apps.

Collected Information & Collection Methodology

1. Third Party Application and Social Media Information

If you access any of Cleebo’s Services on connected third-party applications or connect our Services to any third-party applications, including social networks like Facebook, Cleebo may receive certain information about you from the provider of the third-party application. The information we receive depends on the Cleebo game you’re playing, the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.

For example, Cleebo may collect and store some or all of the following information shared by the provider of the connected third-party application:

• your first and last name;
• your profile picture or its URL;
• your user ID number (for instance your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;
• the user ID number and other public data for your friends;
• the login e-mail you provided to that third-party application when you registered with it;
• your physical location and that of the devices you use to access our Services;
• your gender;
• your birthday and/or age range;
• information about your activities on or through the connected third-party application;
• other publicly-available information on the third-party application; and/or
• any other information that you or the provider of the third-party application share with Cleebo.

If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Policy. If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

2. Cookies and Automated Information

We and service providers acting on our behalf (for instance 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 be able to associate this information with your social network ID or Cleebo 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, and those practices are subject to those companies’ own policies.

If You do not wish to use cookies while accessing the Website it may be possible to disable the use of cookies through changing your internet browser settings or utilizing its “do-not-track” features. For more information on how to limit the types of cookies you allow, please see the section titled Cookie Tracking below.

3. Mobile Device Information

If you play Cleebo games on your mobile device, in addition to your device identifiers, we may also collect:

• the name you have associated with your device;
• your telephone number;
• your country; and
• your specific geolocation;
• your mobile contacts (as further described below in “Information About Your Contacts”); and
• information about Cleebo and other third-party apps you have on your device.

You may be able to control which information We have access to by adjusting the privacy settings on your mobile device. If you want to adjust your privacy preferences on your mobile device, please see How to Access, Update and Manage Your Information.

4. Directly Shared Information

When you use our Services (whether through a social network or through Cleebo 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 Cleebo 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 Cleebo player ID number that is created by Cleebo and used to identify your profile.

Certain information in your Cleebo profile may be publicly accessible on Cleebo’s websites that offer direct access to Cleebo’s games, including:

• The Cleebo player ID;
• Your first and last names; and
• Your player profile picture.

5. 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 Cleebo 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 Cleebo 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.

6. Using Our Communication Features

You may be able to take part in certain activities on our Service that let you communicate or share information not just with Cleebo, but also with other Cleebo players. These include:

• participating in player forums and message boards;
• posting public comments to other players’ profiles;
• 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, drawings or other images.

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 Cleebo’s servers to make use of them to protect the safety and well-being of our player community and Cleebo’s rights and property in connection with 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.

7. Payment Information

If you purchase a license to use in-game virtual currency or virtual items in a game you play on cleebo.com, our third-party payment processor(s) 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. Cleebo does not collect or store your financial information, like credit card numbers. However, Cleebo’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. Cleebo 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.

8. Customer Support Correspondence

Except as provided herein, 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 Cleebo 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 and improve the Services.

9. 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.

10. Game Toolbars or Game Bars

You may have installed a Cleebo-branded toolbar (the “Toolbar”) when playing various games. The Toolbar is based on technology provided by a third party, whose privacy policy is available upon request.

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.

Use of Collected Information

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 Cleebo 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 Cleebo’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 Cleebo, 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 as well as, with your consent, tell you about gifts and other social and game mechanics/features in our games. 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. You may also modify the types of messages you wish to receive by changing your account settings. Receipt of such communications depends on Cleebo having certain contact information from you.

Sharing of Collected 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 in San Francisco) and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

The Service supports and often encourages you to interact with other players. In most Cleebo 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 Cleebo games, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity (including the identification of any Cleebo games you have played), communicate with you within our Services, and view your game profile, which may include your name or a “game name” and your profile photo. In certain cases, your profile photo can reveal your social network ID or Cleebo player ID, and access to a social network ID or Cleebo player ID may allow others to view the public information associated with your related social network profile or Cleebo account. Other players may also be able to send you game requests or even friend requests through the related social network’s or Cleebo’s communication channels.

Third-Party Advertising, Tailoring & Analytics

We may have advertising on our Services so that 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 data regarding our users that may not be tied to a specific user (for instance, age and location data);
• 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 Cleebo or the social network through which you are playing Cleebo’s games.

If you do not want to receive tailored in-application advertisements from third parties, please see Updating and Managing Your Information. Please note that no tailored advertisements will be delivered for Cleebo games designed for children under 13.

Safety, Security and Compliance with Law

Your information, and the contents of all of your online communications in our Services and between you and Cleebo 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 lawful requests by public authorities, including to meet national security or law enforcement requirements, or 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 Cleebo and other applicable third parties, including to enforce our Terms of Service.

Cleebo Offer Walls

Cleebo may display an “offer wall” that is hosted by an offer window provider. The offer wall may allow 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 Cleebo. 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 Cleebo or the social network through which you are playing Cleebo’s games. To properly credit player accounts and to prevent fraud, a unique identifier, in some cases your social network ID or Cleebo player ID, will be shared with the offer window 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 Cleebo undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part its assets, we may disclose or transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to notify users (through the method described in the section titled Changes to Our Privacy Policy) of the business transition before transferring your personal information.

Updating & Managing Your Information

1. Third-Party Applications & Mobile Devices

To manage the information Cleebo receives about you from a third-party application where you play our games, like Facebook, you will need to follow the instructions for the third-party application 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 Cleebo game profile, visit the “Settings” page. 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 Cleebo receives your information from a third-party application or your mobile device, that information is stored and used by Cleebo in accordance with this Privacy Policy. You may access and update that information as described below.

2. Information Held by Cleebo

If you want to review, delete, or change the information Cleebo has about you or have additional questions, e-mail us at privacy@cleebo.com. We will respond to your request within thirty days.

3. Stopping the Use of Your Information

If you no longer want Cleebo to make active use of your information, you may send an e-mail to privacy@cleebo.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.

4. Opting Out of Geolocation

If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device’s settings for the relevant application or the “settings” page for the relevant game.

5. Non-Cleebo Apps

To the extent that Cleebo is collecting information about non-Cleebo apps you have on your device, we will provide you with an option to stop making that information available to us in the “settings” page.

6. Cleebo Emails

Emails we send you may include a web beacon that tells us whether and at what time you have received or opened the email, or clicked a link within the email. If you do not want us to collect this information from our marketing emails, you can opt out of receiving Cleebo marketing emails.

If you want to stop receiving promotional e-mails from Cleebo, click on the “unsubscribe” link in any promotional email from Cleebo 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.

7. 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 app 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.

8. Tailored Advertising

Cleebo utilizes online advertising, including displaying Cleebo advertisements to you across the Internet on websites and in applications. We collect information about which advertisements are displayed, which advertisements are clicked on, and on which web page the advertisement was displayed. Cleebo may permit third parties to place advertisements on our Services.

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 Cleebo. Cleebo 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 Cleebo. Cleebo 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 Cleebo’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.

9. 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 Cleebo cookies are necessary to track and enhance your game activities.

Privacy Policies of Third-Party Services and Advertisers

Our websites and games may contain advertisements from Third-Party Services, which are companies other than Cleebo 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.

Policies Concerning Children

The Cleebo Social Casino is intended for players 21 years of age, or who have reached the age of majority in their jurisdiction . The Services are not directed to children under 13 years old and Cleebo does not knowingly collect personally identifiable information from children under 13. Children below the age of 13 are not permitted to use the Services. 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.

Length of Information Storage

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.

Information Security

We implement security measures to help protect the security of your information both online and offline. We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information.

If you have an account registered directly with Cleebo, your profile information is protected by the password you use to access your Cleebo account. It is important that you protect and maintain your Cleebo account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your Cleebo 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 Cleebo 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 Cleebo account and any social network account you have used to access our Services after you use it.

When you sign into your Cleebo account or enter payment information, we or our third party payment processor use encryption to transmit that information.

While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and 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 privacy@cleebo.com.

Other Jurisdictions

Given the changing and evolving nature of our business, we may be required to locate our servers and other computer systems for the Website in various jurisdictions outside Canada, including the United States and the European Union. Personal information stored on computer systems in those jurisdictions may be subject to different privacy legislation. By using the Services you consent to the transfer of your personal information to such foreign jurisdictions and acknowledge that this may affect the level of protection your personal information is entitled to in light of the different privacy legislation applicable in those jurisdictions.

Third Party Websites

The Services may contain links to third-party websites not operated by Cleebo. It is possible that these links may be used by third parties or others to collect personal or other information about you. If you access a third party website from a link provided through the Services, any information you disclose on that website is not subject to this Privacy Policy. We are not responsible for the privacy practices of any third parties, including any third-party websites. and it is your sole obligation to review and understand the privacy practices and policies of these websites.

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 cleebo.com prior to the change becoming effective. We may supplement this process by sending you a notice to the e-mail address we have on file for you, placing notices on game blogs, social network pages, and/or forums and on other Cleebo websites. You should periodically check www.cleebo.com and this privacy page for updates.

Contact Us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to privacy@cleebo.com.