LAST UPDATED: July 13, 2023
EFFECTIVE DATE: August 5, 2023
PRIVACY POLICY
Clicli Interactive Pte. Ltd. ("Clicli," "we," or "us") wants you to be familiar with how we collect, use and disclose Personal Information. If you are a resident of the European Economic Area ("EEA"), United Kingdom, or any other jurisdictions with applicable data protection laws, Clicli is the controller of your personal data.
"Personal Information" is information that identifies you as an individual or relates to an identifiable individual. This Privacy Policy describes our processing practices of Personal Information that we collect and use in connection with:
- Websites operated by us from which you are accessing this Privacy Policy (the "Websites");
- Gaming and software applications made available by us for use on or through computers, consoles and mobile devices (the "Apps");
- Our social media pages from which you are accessing this Privacy Policy (collectively, our "Social Media Pages"), such as our official fan pages on Twitter, YouTube, and Facebook and fan pages for our individual Apps;
- Email messages that we send to you that link to this Privacy Policy or other communications with you; and
- Offline business interactions you have with us.
Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the "Services."
PERSONAL INFORMATION WE COLLECT
COLLECTION AND PROCESSING OF PERSONAL INFORMATION
DISCLOSURE OF PERSONAL INFORMATION
COOKIES AND SIMILAR TECHNOLOGIES
SECURITY
CHOICES AND INDIVIDUALS' RIGHTS
RETENTION PERIOD
THIRD PARTY SERVICES
OUR ADVERTISING
USE OF THE SERVICES BY MINORS
CROSS-BORDER TRANSFERS
SENSITIVE INFORMATION
UPDATES TO THIS PRIVACY POLICY
CONTACTING US
ADDITIONAL INFORMATION FOR THE EEA / UK
ADDITIONAL INFORMATION REGARDING NEVADA
ADDITIONAL INFORMATION REGARDING CALIFORNIA, COLORADO, CONNECTICUT, UTAH, AND VIRGINIA
NOTICE OF FINANCIAL INCENTIVE / BONA FIDE LOYALTY PROGRAM
PERSONAL INFORMATION WE COLLECT
We collect the following categories of Personal Information:
- Personal Information we receive from you:
| Name & Contact Details | Such as first and last name, title, prefix, email address, telephone number, (instant) messaging account, postal address, date of birth, age, gender, country/region, and government-issued ID such as passport information where as required by applicable laws for age verification and correction of personal information. |
|---|---|
Account Information | Such as your email address, chosen username and password, security questions and answers, avatar, and other information you share in your account. |
| Billing Information | Such as debit or credit card details, bank account details, and billing address. |
| User Content | Such as reviews about our products and Services, and other user-generated content you may create or share on our Services, such as items and assets created or uploaded within our games, and videos and posts on our Social Media Pages, blogs, and comment sections. |
| Gameplay Information | Such as roles, heroes, character appearance, attributes (e.g., level, scores, experience points, and skills), progression and results, virtual currencies, item inventory, tasks and rewards, social connections within the Services, and chat logs. |
| Preferences | Such as** language, interests, other customer feedback/preferences that you might express during your use of our Services, and information you voluntarily provide in our surveys (e.g., your age, education background, occupation, and interests). |
| Marketing Data | Such as your choices regarding our newsletters, surveys, and other marketing/advertising displayed or provided to you, and preferred methods of such promotional communication. |
| Communication History | Such as details of your communications with us, and details of your claims, complaints and queries in general. |
| Transaction Information | Such as details of products and services you have purchased from us, order and purchase history within our Services, including transaction receipt number and purchase amount. |
- Personal Information we collect through your use of our Services or from other sources:
| Social Media Information | Such as name/nickname/username as it appears on your social media account profile, profile pictures, social media account ID, associated email address and other social media profile information, including lists of friends on social media. |
|---|---|
| Location Information | Such as IP geolocation information, cell-ID, and Wi-Fi connection location. |
| Device Information | Such as information about your devices and your use of our Services, such as IP address, MAC address, device identifiers, device model, device operating systems, regional and language settings, internet service provider, screen resolution, frame rate, ping value, stack information (e.g., crash reports and core dumps), server health indicators (e.g., CPU and memory usage, I/O usage, and load average), date and time stamps of actions (e.g., installing or using the Services), advertising identifiers, events within our Services (e.g., logins and gameplay attempts), and events on third-party websites (e.g., engagement time, number of clicks and views, and clicks and views of campaigns and communications materials). This includes data obtained through cookies and similar technologies, as described in the Cookies and Similar Technologies Policy applicable to the specific Service that you are using. |
| Game Account Information | Such as your email address, nickname/username, date of birth, age, country/region, and game account ID, which we collect from Clicli Games Account or the third-party game account (e.g., Xbox account, PSN account, Steam account or Epic Games account) when you use such account to log onto our Services. |
| Third-party Payment Information | Such as a hashed identifier of your account with the third-party payment processing service, and the country/region from which your payment originated. |
COLLECTION AND PROCESSING OF PERSONAL INFORMATION
How we collect Personal Information
We collect Personal Information in a variety of ways, including through our Services and from other sources, as set out in the grid below.
We need to collect certain Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. We will note which Personal Information is required to provide the Services at the time of its collection.
If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Processing of Personal Information
We use your Personal Information for legitimate business purposes as described in the overview below.
Making our products and/or Services available to you
Marketing and user engagement
Personalization and improving our products and/or Services
Security and legal reasons
*For more information on our legal obligations, please see section 'Other Disclosures' below.
DISCLOSURE OF PERSONAL INFORMATION
Connecting Your Services to Social Media
When you connect your Services account to your gaming and/or social media account (e.g., Clicli Games Account, Apple, Discord, Facebook, Google, LINE or Twitter) you will share information with your friends associated with your gaming and/or social media account, with other users, and with your gaming and/or social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the gaming and/or social media account provider's Privacy Policy.
For this sharing of account information, we are jointly responsible with the provider of the third-party gaming and/or social media account. We are, however, not responsible for any other collection or use of your Personal Information by these providers. Depending on the gaming and/or social media account that you choose to connect to your Services account, this means that we are jointly responsible with the following parties for the sharing of your Personal Information:
- Apple, which collects and uses your Personal Information in accordance with the Apple Privacy Policy;
- Discord, which collects and uses your Personal Information in accordance with the Discord Privacy Policy;
- Epic Games,** which collects and uses your Personal Information in accordance with the Epic Games Privacy Policy;
- Facebook, which collects and uses your Personal Information in accordance with the Meta Privacy Policy;
- Google, which collects and uses your Personal Information in accordance with the Google Privacy Policy;
- LINE, which collects and uses your Personal Information in accordance with the LINE Privacy Policy;
- Microsoft, which collects and uses your Personal Information in accordance with the Microsoft Privacy Statement;
- Sony, which collects and uses your Personal Information in accordance with the PlayStation Privacy Policy;
- Steam, which collects and uses your Personal Information in accordance with the Steam Privacy Policy; and
- Twitter, which collects and uses your Personal Information in accordance with the Twitter Privacy Policy.
Other Disclosures
We also disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so, as set out in further detail below.
| Purpose | Further Detail |
|---|---|
| To comply with applicable laws and regulations | This may include laws outside your country of residence, which could give rise to a legal obligation requiring us to process your Personal Information, including: - Civil and commercial matters: where we are in receipt of a court order to disclose information for the purposes of court proceedings, such as under Regulation (EU) 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters. - Criminal matters: to comply with requests and orders from applicable law enforcement agencies to provide information in relation to a criminal investigation in compliance with applicable local laws, or to take steps to report information we believe is important to law enforcement where so required or advisable under applicable local laws. - Consumer matters: to comply with requests from competent authorities under applicable consumer protection law, such as under Directive (EU) 2019/2161 and its implementing laws in EU Member States. - Corporate and taxation matters: to comply with our obligations under applicable corporate and tax legislation, such as where a national tax law of an EU Member State requires collection of specific transactional personal information for tax purposes. - Regulatory matters: to respond to a request or to provide information we believe is necessary or appropriate to comply with our obligations to engage with regulators, such as when relevant EU Member State data protection supervisory authorities initiate investigation under the General Data Protection Regulation into Clicli. These can include authorities outside of your country of residence. - Compliance and internal investigations: to comply with whistleblowing requirements under Directive (EU) 2019/1937 and its implementing laws in EU Member States. - Health and safety regulations: to comply with health and safety reporting obligations in accordance with applicable local laws, such as in relation to accidents involving members of the public on our premises. - Age verification and KYC regulations: to comply with Know Your Customer and age verification requirements for the online gaming sector. |
| For other legal reasons | - For dispute resolution purposes; - To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. |
| In connection with a sale or business transaction | We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). |
COOKIES AND SIMILAR TECHNOLOGIES
Where applicable, we may collect Personal Information through the use of cookies and similar technologies, which allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences and other traffic data. We do not currently respond to browser do-not-track signals. To learn more about how we use cookies, or to opt out of the collection and use of cookies, please see the Cookies and Similar Technologies Policy applicable to the specific Service(s) that you are using.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contacting Us" section below.
CHOICES AND INDIVIDUALS' RIGHTS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
- Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by contacting us at support@theclicli.com.
- Receiving marketing-related push notifications from us. If you no longer want to receive marketing related push notifications from us on a going-forward basis, you may opt out by disabling push notifications for the relevant App on your device.
- Our sharing of your Personal Information with affiliates for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by contacting us at support@theclicli.com.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing from us, we may still send you important administrative messages, from which you cannot opt out.
How you can exercise your rights
You have certain rights in relation to the Personal Information we hold about you. These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to erase information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR/UK GDPR and in relevant local implementing legislation.
- Access: You have the right to access Personal Information we hold about you and to certain information about the processing of that information. To exercise this right, please contact us at support@theclicli.com or contact the in-game customer service.
- Portability: You have the right to receive a copy of certain Personal Information we process about you. This comprises any Personal Information we process on the legal basis as described in the section "Collection and Processing Of Personal Information." You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that Personal Information to another party. If you wish for us to transfer such Personal Information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible.
- Correction: You have the right to rectify/correct any Personal Information about you that is inaccurate. To exercise this right, please contact us at support@theclicli.com or contact the in-game customer service.
- Erasure: You can delete your account, or request the erasure of your Personal Information in certain circumstances. If you would like to make such an erasure request, please contact us at support@theclicli.com or contact the in-game customer service. We may need to retain Personal Information if there are valid grounds under data protection laws for use to do so (e.g., for the defense of legal claims or freedom of expression).
- Restriction of Processing to Storage Only: You have a right to request us to stop processing the Personal Information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Personal Information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or for another's protection).
You may request us to step processing and just to store the Personal Information we hold about you where:
- you believe the Personal Information is not accurate for the period it takes for us to verify whether it is accurate;
- you wish to erase the Personal Information as the processing we are doing is unlawful but you want us to retain the Personal Information but just store it instead; or
- you wish to erase the Personal Information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims.
- Objection: You have the right to object to our processing of Personal Information about you where we are pursuing our legitimate interests or those of a third party. You may send your request by contacting us at support@theclicli.com or contacting the in-game customer service.
- Right to Withdraw Your Consent: Where we reply on your consent to process your Personal Information, you have the right to withdraw this consent at any time. Please note that withdrawing this consent will not affect the lawfulness of how we processed your Personal Information before you withdraw it.
We will respond to your request consistent with applicable laws. In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
You may lodge a complaint with the protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available at LINK. You can file a complaint with the UK ICO at LINK.
RETENTION PERIOD
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Where a legal obligation arises or retention is advisable in light of our legal position, in some circumstances, we will retain certain Personal Information, even after your account has been deleted and/or we no longer provide the Services to you; for example:
- To cooperate with law enforcement or public, regulatory and government authorities: If we receive a preservation order or search warrant, related to your Services account, we will preserve Personal Information subject to such order or warrant after you delete your Services account.
- To comply with legal provisions on tax and accounting: We may retain your Personal Information, such as Billing Information, Communication History, and/or Transaction Information, for up to 7 years after you delete your Services account, as required by tax law and to comply with bookkeeping requirements.
- To pursue or defend a legal action: We may retain relevant Personal Information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your Personal Information, or if we reasonably believe there is a prospect of litigation (whether in respect of our relationship with you or otherwise) for up to 7 years after the dispute has been settled or decided by a court or tribunal from which there is no further right of appeal.
In some circumstances we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
THIRD PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third-party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
The Services may provide functionality allowing you to make payments to the company using third-party payment processing services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third parties and not by us and will be subject to the third party's privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party's collection, use, and disclosure of your Personal Information.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Apple, Discord, Epic Games, Facebook, Google, LINE, Microsoft, Sony, Steam, Twitter, or any other app developer, app provider, gaming and/or social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
OUR ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
- With your consent, you may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit aboutads. You may download the AppChoices app at [www.aboutads.info/appchoices]aboutads to opt out in mobile apps.
- With your consent, we share your hashed email address and limited app analytics information (e.g., whether you have installed the app or have recently opened the app) with Google Ads to show relevant ads, and measure ad performance, when you are using third-party applications and websites. We will only share hashed or encrypted identifiers with Google and not directly identifying information such as your name or email address for this purpose. You can always withdraw your consent via "Account Center" – "Ads Settings" in your account if you do not wish to be shown personalized ads outside of our game.
USE OF THE SERVICES BY MINORS
We are committed to respecting children's privacy. We may request your age-related information to ensure that we provide you with age-appropriate Services and to comply with applicable laws. If you are under the age of 13 or under such higher minimum age applying in your jurisdiction, you may be blocked from using some of our Services.
CROSS-BORDER TRANSFERS
We store your Personal Information in data centers located in Japan. Your Personal Information may be transferred to countries or regions outside of your country of residence where we have corporate entities and third-party service providers, which may have data protection rules that are different from those of your country. These entities commit to processing information in compliance with applicable data protection laws and to implementing appropriate security measures to protect your Personal Information.
SENSITIVE INFORMATION
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to gender or gender expression, racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.
UPDATES TO THIS PRIVACY POLICY
The "LAST UPDATED" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective at the date indicated in the "EFFECTIVE DATE" legend at the top of this Privacy Policy.
CONTACTING US
If you have any questions about this Privacy Policy, please contact us at support@theclicli.com.
You can also contact us at:
Clicli Interactive Pte. Ltd.
10 COLLYER QUAY, #10-01 OCEAN FINANCIAL CENTRE, SINGAPORE
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
ADDITIONAL INFORMATION FOR THE EEA / UK
Where this will involve transferring your Personal Information outside the UK, EEA and/or Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Adequacy Decisions: Some non-EEA countries are recognized by the UK, the EEA and/or Switzerland as providing an adequate level of data protection according to UK/EEA/Swiss standards (the full list of these countries is available here for the EU Commission, here for the UK Information Commissioner, and here for the Swiss Federal Data Protection and Information Commissioner. We rely on the adequacy decisions for transfers to countries as described here.
Standard Contractual Clauses: For transfers of Personal Information from the UK, EEA and/or Switzerland to countries which are not considered adequate, including transfers to our corporate entities listed here, we have put in place standard contractual clauses issued under the UK GDPR and/or by the European Commission (for transfers from Switzerland with the required amendments) to protect your Personal Information.
You may obtain a copy of these measures by contacting us in accordance with the "Contacting Us" section above.
ADDITIONAL INFORMATION REGARDING NEVADA
We do not sell Covered Information as defined under Nevada law. If you would like to make any inquiry regarding the sale of your Covered Information, please contact us at support@theclicli.com.
ADDITIONAL INFORMATION REGARDING CALIFORNIA, COLORADO, CONNECTICUT, UTAH, AND VIRGINIA
This section supplements the above Privacy Policy and further describes how we collect, use, and disclose the Personal Information we collect about California, Colorado, Connecticut, Utah, and Virginia consumers. This section does not apply to Personal Information that we collect from our job applicants, contractors, or employees.
Notice at Collection
Collection, Processing, Disclosure, and Sharing of Personal Information
The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes, including within the preceding 12 months. The chart also details the categories of Personal Information that we "share" for purposes of cross-context behavioral or targeted advertising, including within the preceding 12 months.
| Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes | Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising | Processing Purposes (See the chart above for a detailed description of each Processing Purpose) |
|---|---|---|---|
Identifiers, such as: - Contact information: name, postal address, email address - Unique personal identifiers: IP address, account name, username, social media handle, avatar, (instant) messaging account, account ID, device ID, advertising ID, MAC address, online identifiers | Affiliates; other users; service providers who provide services such as website and game hosting, payment processing, surveys, data analytics, customer support, email delivery, marketing and advertising, legal and auditing, and information technology and related infrastructure services; gaming and social media platforms; law enforcement, public, regulatory and government authorities, courts or tribunals; sponsors of contests and similar promotions | - Ad networks, including social media providers | - Providing the functionality of the Services - Providing location-based services - Customer support - Communicating important changes/Service messages - Operations and general business - Marketing - Promotions and contests - Relationship building and engagement - Personalizing our Services - Improving and developing new products and Services - Fraud prevention and security - Anti-cheating - Legal and compliance |
Personal information as defined in the California customer records law, such as - Contact Information: name, postal address, telephone number - Physical characteristics or description | Affiliates; other users; service providers who provide services such as website and game hosting, customer support, email delivery, marketing and advertising, legal and auditing, and information technology and related infrastructure services; law enforcement, public, regulatory and government authorities, courts or tribunals; sponsors of contests and similar promotions | None | - Providing the functionality of the Services - Customer support - Communicating important changes/Service messages - Operations and general business - Marketing - Promotions and contests - Relationship building and engagement - Improving and developing new products and Services - Fraud prevention and security - Legal and compliance |
| Protected Class Information, such as characteristics of protected classifications under California or federal law, such as age (date of birth), race (e.g., derived from a profile picture), gender (gender expression or gender identity voluntarily provided by you), national origin | Affiliates; other users; service providers who provide services such as website and game hosting, data analytics, customer support, email delivery, legal and auditing, and information technology and related infrastructure services; law enforcement, public, regulatory and government authorities, courts or tribunals | None | - Providing the functionality of the Services - Customer support - Communicating important changes/Service messages - Operations and general business - Relationship building and engagement - Improving and developing new products and Services - Fraud prevention and security - Legal and compliance |
| Commercial Information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories, tendencies, or preferences | Affiliates; other users; service providers who provide services such as website and game hosting, payment processing, surveys, data analytics, customer support, email delivery, marketing and advertising, legal and auditing, and information technology and related infrastructure services; gaming and social media platforms; law enforcement, public, regulatory and government authorities, courts or tribunals | - Ad networks, including social media providers | - Providing the functionality of the Services - Customer support - Communicating important changes/Service messages - Operations and general business - Marketing - Relationship building and engagement - Personalizing our Services - Improving and developing new products and Services - Fraud prevention and security - Legal and compliance |
| Internet or network activity information, such as browsing history, search history, or any information on a consumer's interaction with a website, application, or advertisement or service, including game data | Affiliates; other users; service providers who provide services such as website and game hosting, payment processing, data analytics, customer support, email delivery, marketing and advertising, legal and auditing, and information technology and related infrastructure services; law enforcement, public, regulatory and government authorities, courts or tribunals; sponsors of contests and similar promotions | - Ad networks, including social media providers | - Providing the functionality of the Services - Customer support - Communicating important changes/Service messages - Operations and general business - Marketing - Promotions and contests - Relationship building and engagement - Personalizing our Services - Improving and developing new products and Services - Fraud prevention and security - Anti-cheating - Legal and compliance |
| Geolocation Data, such as postal address, approximate location derived from IP address, cell-ID, Wi-Fi connection location | Affiliates; other users; service providers who provide services such as website and game hosting, data analytics, customer support, marketing and advertising, legal and auditing, and information technology and related infrastructure services; law enforcement, public, regulatory and government authorities, courts or tribunals; sponsors of contests and similar promotions | None | - Providing location-based services - Customer support - Operations and general business - Marketing - Promotions and contests - Fraud prevention and security - Legal and compliance |
| Audio/Video Data. Audio, electronic, visual, and similar information, such as profile photo, electronic information you provide directly or through your interactions with our Services (e.g., device model, internet service provider, operating system, date and time stamp of actions) | Affiliates; other users; service providers who provide services such as website and game hosting, payment processing, data analytics, customer support, email delivery, marketing and advertising, legal and auditing, and information technology and related infrastructure services; gaming and social media platforms; law enforcement, public, regulatory and government authorities, courts or tribunals; sponsors of contests and similar promotions | - Ad networks, including social media providers | - Providing the functionality of the Services - Customer support - Communicating important changes/Service messages - Operations and general business - Marketing - Promotions and contests - Relationship building and engagement - Personalizing our Services - Improving and developing new products and Services - Fraud prevention and security - Anti-cheating - Legal and compliance |
| Employment Information. Professional or employment-related information, such as occupation | Affiliates; service providers who provide services such as surveys, and data analytics; law enforcement, public, regulatory and government authorities, courts or tribunals | None | - Operations and general business - Relationship building and engagement - Improving and developing new products and Services - Fraud prevention and security - Legal and compliance |
| Inferences drawn from any of the Personal Information listed above to create a profile reflecting a consumer's preferences | Affiliates; service providers who provide services such as website and game hosting, data analytics, customer support, email delivery, marketing and advertising, legal and auditing, and information technology and related infrastructure services; law enforcement, public, regulatory and government authorities, courts or tribunals | None | - Providing the functionality of the Services - Customer support - Communicating important changes/Service messages - Operations and general business - Marketing - Relationship building and engagement - Personalizing our Services - Improving and developing new products and Services - Fraud prevention and security - Legal and compliance |
Sensitive Personal Information - Account log-in in combination with any required security or access code, password, or credentials allowing access to an account - Racial or ethnic origin (e.g., derived from a profile picture or avatar) | Affiliates; other users; service providers who provide services such as website and game hosting, data analytics, customer support, email delivery, legal and auditing, and information technology and related infrastructure services; law enforcement, public, regulatory and government authorities, courts or tribunals | None | Please see the section below, entitled "Collection, Processing, and Disclosure of Sensitive Personal Information." |
We may also process your Personal Information or disclose it to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). We do not "sell" Personal Information, as that term is defined under applicable state privacy laws.
Collection, Processing, and Disclosure of Sensitive Personal Information
Subject to your consent where required by applicable law,** we collect, process, and disclose Sensitive Personal Information for purposes of: providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, storage, or similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about a consumer.
We do not use Sensitive Personal Information beyond these purposes.
Retention Period
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
GO TO TOP OF PRIVACY POLICY
Rights and Requests
You may, subject to applicable law, make the following requests:
- To know whether we process your Personal Information, and to access such Personal Information. If you are a California consumer, you may also request that we disclose to you the following information:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The business or commercial purpose for collecting or "sharing" Personal Information about you;
- The categories of Personal Information about you that we "shared" and the categories of third parties to whom we "shared" such Personal Information; and
- The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information.
- To correct inaccuracies in your Personal Information.
- To have your Personal Information deleted.
- To receive the specific pieces of your Personal Information, including a copy of your Personal Information in a portable format.
- To opt out of targeted advertising, including the "sharing" of your Personal Information for cross-context behavioral advertising.
You have the right not to be unlawfully discriminated against for exercising your privacy rights.
To make a request under #1-4, above, please email us at support@theclicli.com or contact the in-game customer service. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may decline to honor your request where an exception applies.
If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. We may need to request your name, email address, and other information regarding your interactions with us, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.
To request to opt out of any future "sharing" of your Personal Information for purposes of cross-contextual behavioral advertising, or any future processing for purposes of targeted advertising, if you're logged in, you may set your preference via "Account Center" – "Ads Settings" in your account, or if you're not logged in or don't have an account with us, you may set your preference by clicking "Do Not Share My Personal Information" link at the bottom of the applicable web pages.
Additionally, certain browser plug-ins provide options for communicating opt-out preference signals, such as the Global Privacy Control ("GPC"). We treat GPC signals as a request to opt-out of targeted advertising or the "sharing" of personal information in relation to your browser or device that sends the GPC signal. If you are not logged into your account, the request through the GPC signal will not extend to any account information, as the connection between your browser or device and account is not known to us.
We do not knowingly "sell" or "share" Personal Information (including Sensitive Personal Information) of minors under 16 years of age.
Appeal Process
If you are a Colorado, Connecticut, or Virginia consumer and if we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by emailing us at support@theclicli.com or contacting the in-game customer service.**
Authorized Agents
If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled "Rights and Requests." We will process the agent's request consistent with applicable law. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled "Rights and Requests" or confirm that you provided the agent permission to submit the request.
Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.
Removal of Publicly Posted Content
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by emailing us at support@theclicli.com or contacting the in-game customer service. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
NOTICE OF FINANCIAL INCENTIVE / BONA FIDE LOYALTY PROGRAM
The California Consumer Privacy Act's implementing regulations define a "financial incentive" as a program, benefit, or other offering "for the collection, retention, sale, or sharing of personal information." Likewise, the Colorado Privacy Act's implementing rules define a "Bona Fide Loyalty Program" as a program "established for the genuine purpose of providing discounts, rewards, or other actual value" to members that voluntarily participate. Clicli offers users the opportunity to obtain nominal in-game currency and other rewards ("Rewards"), which may provide benefits to those who choose to participate ("Members").
Our collection of Members' Personal Information (including name, email address, and phone number) allows Clicli to provide Rewards. Clicli uses the Personal Information of Members to both award and redeem benefits. The amount of Personal Information that we collect from a Member or non-Member may vary and is dependent on the level of interactions and engagement that the Member or non-Member has with Clicli, including the type of Rewards in which the Member chooses to participate.
Clicli uses Personal Information for marketing and other purposes described above in the section entitled "Collection, Processing, Disclosure, and Sharing of Personal Information." We also use for targeted advertising or “sharing,” as the term is defined under the California Consumer Privacy Act, the Personal Information of both Members and non-Members. The following details are disclosed above in the section entitled "Collection, Processing, Disclosure, and Sharing of Personal Information":
- Categories of Personal Information processed for purposes of targeted advertising; and
- Categories of third parties that will receive Members' Personal Information.
The types of Personal Information that we collect from Members who participate in Rewards are generally similar to the types of Personal Information that we collect from consumers who do not participate in Rewards. We do not collect Sensitive Personal Information in connection with Rewards.
We estimate the value of a Member's Personal Information to Clicli, solely for purposes of the California Consumer Privacy Act and pursuant to the valuation options mandated by the Act's regulations, to be reasonably related to the value of the benefits that Members obtain through participating in Rewards. We have based this good faith estimate on the value that arises from increased customer interactions, the costs and expenses Clicli incurs in offering Rewards, the types of Rewards provided, and the collection and retention of the Personal Information of consumers who have voluntarily chosen to participate in Rewards. The value of Rewards to Members varies significantly as individual Members take advantage of Rewards to varying degrees.
Members who are California or Colorado consumers may exercise their privacy rights, including the rights to know, correct, to request deletion, and to opt out of the "sharing" of Personal Information or the use of Personal Information for targeted advertising, without any effect on their eligibility to participate in Rewards. A Member may also choose not to receive marketing communications or offers at any time without any effect on their eligibility to participate in Rewards.
A Member's opt-in consent to Rewards may be revoked at any time. Members may revoke their consent and opt out of Rewards by emailing us at support@theclicli.com or contacting the in-game customer service.
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