Skillsgapp Privacy Policy

 

This skillsgapp Privacy Policy (“Privacy Policy”) includes the matter in which we collect, use, secure, and share information in connection with our games, mobile apps, websites, content, and any related services (collectively the “Services”), and your choices regarding that information. For purposes of this Privacy Policy, “skillsgapp” (or “we” or “us”) refers to skillsgapp llc and its subsidiaries, representatives, affiliates, officers, and directors.

 

When there are updates to the Privacy Policy, we will notify you prior to the changes becoming effective through the Services, or by other means if you’ve provided us additional contact information (e.g., using the email address associated with your Account, as defined in our Terms of Use). We will also post a new version of the policy on skillsgapp.com with an updated date. Your continued use of the Services after the Effective Date will be an acknowledgement of our updated practices.

 

Collection of Your Information

 

We collect the information you provide to us directly from the information collected from your devices (including web), and from information collected from other sources, like social networking sites and gaming partners. Some of this information may be considered “personal information” or “personal data” under applicable privacy or data protection laws.

 

The Information Provided By You

 

You are providing information directly to skillsgapp when you:

 

Use or access the Services, including when you create a skillsgapp Account (as defined in our Terms);

 

Connect with or access our Services using a third-party ID or log-in, such as an ID for a social networking site or gaming service;

Communicate with or contact others using our Services, including when you use chat, “invite a friend,” “email this page,” or other similar features;

Contact us, including for customer or technical support;

 

Subscribe to newsletters or sign up to hear about current or upcoming products); and/or

 

Complete surveys offered by us or on our behalf;

 

Depending on how you choose to use the Services, you may provide us with the following information:

 

Things like your first and last name, username or handle, third party service ID, email address, phone number, home address or shipping address, and other contact information;

 

Your photo, avatar or other image;

 

Your date of birth, and gender;

 

Purchase or payment information;

 

Other information such as chat records, friends’ names and contact information, and non-precise location information you choose to share (for example, when you connect with our Services through social features).

 

The Information Collected When You Use our Services

 

When you utilize our Services, we collect information from you, about you, and the device(s) you use. This includes:

 

IP address, unique device identifiers, advertising identifiers, device serial numbers, and similar identifiers.

 

Hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, or clickstream data.

 

Approximate location inferred from IP address.

 

Game scores and achievements, and other information required to enhance our Services.

 

The Information Collected Through Cookies and Similar Technologies

 

Skillsgapp, our affiliates and partners may use cookies, beacons, software development kits, mobile analytics software, and/or similar technologies for a number of purposes, including to authenticate users, prevent fraud, remember preferences and settings, analyze advertising and messaging campaigns, analyze traffic and trends, personalize content (including ads), and otherwise provide the Services. These technologies may collect information about your use of our Services, pages you view, links you tap, messages you open, and other actions taken in connection with our Services.

 

Depending on the choices and settings available for the browser(s) you use, you may be able to disable cookies in your browser settings, but this could affect the availability and functionality of our Services. For information on interest-based advertising and how to opt out, see the Interest-Based Advertising section below.

 

The Information Collected Through Social Networks

 

Some of our Services incorporate features offered by social networks and other third-party sites. If you choose to take advantage of these features, we may collect additional information you choose to share with us, like:

 

Your name, user ID, social username, and contact information;

 

Your gender, age, date of birth, and language preference;

 

Your profile picture and the profile pictures of your friends or contacts;

 

Other information such as time zone, the organizations and links on your profile page, the names of your friends or contacts, and other information you share in connection with your profile.

 

If you allow contact information to be shared with us, we may use that information to communicate with you or with your invited friends as described in this Privacy Policy and as further described at the time you choose to share that information (for example, we may suggest friends to play with, or may help you invite a friend to play with you).

 

The Information Collected From Other Sources

 

We may collect information about you from other sources, including from our third-party partners or service providers, publicly available sources, feedback from other players, or social networking sites. We may combine this information with other information in our possession, which helps us to update, enhance, and analyze our Services.

 

The Purpose Of This Information

 

Skillsgapp uses this information for a number of business and commercial purposes, including:

 

Performing internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing, and research;

 

Understanding how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns), as well as offer discounts or personalized pricing;

 

Maintaining the safety, security, and integrity of our Services, for example by authenticating users and providing account security and fraud detection;

 

Sending you news and/or marketing communications (by email, phone, or text), including information about skillsgapp or third-party offerings we think may be of interest to you;

 

Administering contests, surveys and sweepstakes you enter, and notify contest winners and award prizes;

 

Fulfilling a purchase or send you order confirmations or other requested product or Service information;

 

Facilitating your communication with friends and other users, and enable features that allow you to share information with other people (for example, if you choose to use friend invite features); and/or

 

Complying with legal requirements and/or to investigate or address claims or disputes relating to your use of the Services.

 

How We Share Your Information

 

We may share your information in a variety of ways, including:

 

With vendors, consultants, business partners, payment processors, and other third-party service providers as necessary to carry out work on our behalf and otherwise provide the Services;

 

With other players, to enable you to interact with them and to share gameplay-related data such as high scores and other leaderboard information;

 

With the general public, if you choose to share information when contributing content to our Services through a forum, blogs, social features, or the like;

 

Where you choose to take advantage of social sharing features or related tools that let you share games and other actions you take on our Services, with the public, social media platforms, and/or your social media friends or contacts;

 

With others who share your device, if you make your Account available to them through that device;

 

With specific third parties if we believe disclosure is required by applicable law, regulation, or legal process;

 

With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our terms or other policies, and/or are fraudulent or in violation of applicable law, or as we determine necessary to protect the rights, property, or safety of skillsgapp or others;

 

In connection with a merger, consolidation, restructuring, sale of company stock and/or assets or other corporate change, including during the course of any due diligence process; and/or

 

In an aggregated form or otherwise in a form that cannot reasonably be used to identify you.

 

In some cases, we may provide you access to third-party products or services through our Services. Please note that those products or services are offered by people or companies not affiliated with or controlled by us, and we are not responsible for their actions, their terms, their use of information, or their products or services. If you submit your information to a third party, that third party’s treatment of your information is governed by their privacy policy, which may differ from this Privacy Policy.

 

We also share information with your consent or direction. For example, we may share your personal data if you opt in to receive information from skillsgapp’s business partners.

 

Interest-Based Advertising

 

We work with third-party advertising partners, and may share your information to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. They or we may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences.

 

If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may do so through your device settings (“Limit Ad Tracking” on iOS and “Opt Out of Ads Personalization” on Android). Please note that you may continue to receive generic ads that are not based on your preferences.

 

Your Rights and Choices

 

You can update your personal and other information in your Account or in-app at any time. You can manage your information as described below, and you may have additional rights related to that information as described elsewhere in this Privacy Policy.

 

Updating or Changing Your Data

 

It is your responsibility to maintain accurate, complete, and up-to-date information in connection with your Account in-app.

 

Deleting Your Data

 

You may request deletion of personal information we have collected and stored about you, subject to our Data Retention policy described below. If you have played multiple skillsgapp games and want to have your personal information deleted as to all of them, please contact hello@skillsgapp.com for help. Please also note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and if you share devices with someone else who uses the Services, that person may lose game progress or related account information and access. If you decide to use or access the Services again, skillsgapp may consider this a new Account and may collect personal information associated with that Account in accordance with this Privacy Policy.

 

Communication Preferences

 

We may contact you at the email address(es) or phone number(s) provided in connection with your Account. You may opt out of these messages by following the unsubscribe instructions in the message (e.g. by tapping an unsubscribe link or replying “STOP”) or by contacting us at hello@skillsgapp.com.

 

In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer wish to receive them, you can turn them off at the device level.

 

Most web browsers are set to accept cookies by default. If you prefer, you can set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

 

Other Rights

 

In some cases, particularly if you are a resident of the EEA, the United Kingdom, or Switzerland, or if you are a resident of the State of California, you may have additional rights with respect to your personal data or personal information as defined under applicable laws. For more information on these rights, please refer to the additional disclosures below.

 

Data Retention

 

We may retain personal information required by law, or when we have an ongoing legitimate business need to do so. For example, we may retain such information to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, enforcement of our contracts and terms, or for safety reasons (e.g., we may retain certain information about an Account to prevent that user from opening a new Account).

 

Security

 

We follow industry standards to maintain safeguards designed to secure the information in our possession, and only those at skillsgapp with a legitimate business need to access your personal information are permitted to do so. We also utilize best practices to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us at hello@skillsgapp.com.

 

Use by Minors

 

We do not knowingly collect or process personal data from or about, or direct or target interest-based advertising to, anyone under the age of 13 (or under the age of 16 for those in the EEA, United Kingdom, or Switzerland), nor do we knowingly allow such individuals to use our Services. If you believe we might have any data from or about a child under this age, please contact us at hello@skillsgapp.com. If we learn that we have inadvertently gathered such information, we will delete it.

 

Additional Information for Residents of the EEA, United Kingdom, and Switzerland

 

Rights and Choices Available to EEA Residents

 

If you are a resident of a member country of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you may have the following rights with respect to any information about you that constitutes “personal data” under EEA law:

 

Access your personal data: You may have the right to obtain confirmation regarding whether we process your personal data and obtain a copy of the personal data we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)

 

Rectify or correct your personal data: You may have the right to correct your personal data where it contains inaccuracies.

 

Request erasure (deletion) of your personal data: You may have the right to request that skillsgapp delete your personal data in certain cases, for example when it is no longer necessary to fulfill the purposes for which skillsgapp collected it. This right may be limited to the extent that skillsgapp is permitted or required by applicable law to retain the data. (Note that if you request deletion of your personal data, you may no longer be able to use or access the Services. If you share devices with someone else who uses the Services, that person may also lose game progress or related account information and access. If you decide to use or access the Services again, skillsgapp may consider this a new Account and may collect personal data associated with that Account in accordance with this Privacy Policy.)

 

Restrict or object to the processing of your personal data: In certain cases, you may have the right to object to skillsgapp’s processing of your personal data, or request that skillsgapp restrict that processing. Because the data that skillsgapp collects is generally required to provide the Services to you, if you object to the processing of your personal data, this may have the same effect as requesting deletion of this data. This right may be limited to the extent that skillsgapp is permitted or required by applicable law to continue processing the data. (Note that if you object to the processing of your personal data, you and others who use your devices to access the Services may no longer be able to use or access the Services.)

 

Request a portable copy of your personal data: In certain limited cases, you may be able to request that skillsgapp provide you with a copy of your personal data in a structured, commonly used and machine-readable format so that you can transmit it elsewhere.

To protect the privacy of your information, skillsgapp verifies your identity and processes all rights requests through our in-game help system. If you wish to exercise any of the rights described above, please follow the instructions below and do not delete the game until your request is fulfilled:

1.    Open the skillsgapp game(s) for which you wish to exercise your rights, and open an in-game help ticket via the Help section for that game. (If you have played multiple skillsgapp games and want to exercise rights as to all of them, please open a help ticket directly in-game via the Help section for each of those games.)

2.    Once you have opened a help ticket, please clearly state which right(s) you wish to exercise for that game. For example, you can say “I want to delete my personal data,” or “please provide me with access to my personal data.” We cannot begin processing your request until you have clearly stated which right(s) you wish to exercise.

3.    Make sure to include your city and country of residence in your request. We cannot begin processing your request until you have confirmed your residence. We will only use this information in order to fulfill and document your request.

4.    Repeat the above steps for any other games for which you would like to make a request.

 

If you have trouble with any of the steps described above, you can contact hello@skillsgapp.com for help. We may contact you to confirm your choices and to ask for additional information as needed to verify your identity and process your request.

 

In addition to the rights described above, if we have collected and process certain types of personal data with your consent, you may withdraw that consent in the manner described when you provided consent. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to then, nor will it affect any processing based on lawful grounds other than consent.

 

In some cases, you may have the right to file a complaint with a data protection authority about our collection and use of your personal data. For more information, contact your local data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.

 

Legal Basis for Processing Personal Data

 

If you are from the EEA, the United Kingdom, or Switzerland, our legal basis for collecting and using your personal data will depend on the type of information and the context in which we collect it. In general, we collect personal data from you only where we have your consent to do so, where we need it to perform a contract with you, or where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need it to protect your vital interests or those of another person. If you have questions about the legal basis on which we collect and use your personal data, please contact us.

 

EU-US and Swiss-US Privacy Shield Principles

 

We comply with the EU-US and Swiss-US Privacy Shield Principles regarding the collection, use, sharing, onward transfer, and retention of personal data received from the European Union (EU), the United Kingdom, and Switzerland, as described in our EU-US and Swiss-US Privacy Shield certifications. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]. Privacy Shield participants are subject to the regulatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal data from the EU or Switzerland to third parties outside the EU and Switzerland.

 

If you have a Privacy Shield-related complaint, please contact us. If you feel your complaint remains unresolved after doing so, you may contact our US-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions more fully described at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke the Privacy Shield binding arbitration process when other dispute resolution procedures have been exhausted. In certain situations, skillsgapp may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

Residents of California: Information We Collect, Use, and Disclose

 

California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in the “Information We Collect and How We Collect It,” “How We Use Information,” and “How We Share Information” sections of this Privacy Policy.

 

Generally, we collect the following categories of personal information, as defined by applicable California law:

 

Identifiers and contact information, including first and last name, username or handle, third party service ID, IP address, unique device identifier, advertising identifier, device serial number, email address, phone number, home address or shipping address, and your friends’ names and contact information;

 

Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream data;

 

Commercial information, including in-game purchase information;

 

Demographic information, including your gender, age, date of birth, and language;

 

Non-precise geolocation information, such as approximate location as inferred from IP address;

 

Visual information, such as your profile picture and the profile pictures of your friends or contacts; and

 

Other information you may share if you use social features when accessing our Services, including the organizations, links, and other information included on your social profile pages.

 

In the past 12 months, we have disclosed (or have enabled you to disclose) the following categories of personal information to third parties for business or commercial purposes:

 

·      Identifiers and Non-precise location information (e.g., estimated location based on your IP address) with: cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use); payment processors; analytics providers; and advertising networks.

 

·      Internet and electronic network activity information with: cloud service providers (such as our email service providers and cloud-based survey and customer service tools we use); and analytics providers.

 

·      Commercial information and Demographic information (e.g., gender, age, date of birth, and language) with: cloud service providers (such as cloud-based customer service and survey tools we use).

 

·      Visual information (such as your profile picture) with: service providers that enable photograph functionality on our behalf.

If the skillsgapp games you play are supported by ads or third-party features and enhancements, we allow our partners to collect certain device identifiers, performance and activity levels, and electronic network activity via our Services to show ads that are targeted to your interests. To opt out of having your personal information used for targeted advertising purposes, please see the Interest-Based Advertising section above.

 

Residents of California: Rights and Choices

 

If you are a California resident, you may have the following rights with respect to any information about you that constitutes “personal information” under California law:

 

Access your personal information: You may have the right to obtain a copy of the specific pieces of personal information we have collected about you. (Note that this right only applies to personal information relating to you, and not to any other player.)

 

Request deletion of your personal information: You may have the right to request that skillsgapp delete your personal information. This right may be limited to the extent that skillsgapp is permitted or required by applicable law to retain information. (Note that if you request deletion of your personal information, you may no longer be able to use or access the Services, and that if you share devices with someone else who uses the Services, that person may lose game progress or related account information and access. If you decide to use or access the Services again, skillsgapp may consider this a new Account and may collect personal information associated with that Account in accordance with this Privacy Policy.)

 

Obtain additional details regarding skillsgapp’s information practices: You may have the right to request disclosures regarding skillsgapp’s information practices. (Note that this information is generally available in this Privacy Policy.)

 

To protect the privacy of your information, when you exercise any of these rights, skillsgapp verifies your identity and processes all rights requests through our in-game help ticket system. Please do not delete the game until your request is fulfilled. If we are unable to process your request via our in-game help ticket system, we may verify your request by asking for information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us or with one of our games.  

 

If you wish to exercise any of the rights described above, please follow the instructions below:

1.    Open the skillsgapp game(s) for which you wish to exercise your rights, and open an in-game help ticket via the Help section for that game. (If you have played multiple skillsgapp games and want to exercise rights as to all of them, please open a help ticket directly in-game via the Help section for each of those games.)

2.    Once you have opened a help ticket, please clearly state which right(s) you wish to exercise for that game. For example, you can say “I want to delete my personal information,” or “please provide me with access to my personal information.” We cannot begin processing your request until you have clearly stated which right(s) you wish to exercise.

3.    Make sure to include your city and country of residence in your request. We cannot begin processing your request until you have confirmed your residence. We will only use this information in order to fulfill and document your request.

4.    Repeat the above steps for any other games for which you would like to make a request.

 

If you have trouble with any of the steps described above, you can contact hello@skillsgapp.com for help. We may contact you to confirm your choices and to ask for additional information as needed to verify your identity and process your request.

We will never discriminate against you for exercising any of your rights under California law.

 

Contact Us

 

If you have questions or concerns about this Policy or our data practices, you can contact us by email at hello@skillsgapp.com, or by postal mail at: skillsgapp, Inc., Attn: Legal, PO Box 25777 Greenville, SC  29616. If we receive a formal written complaint from you, we will attempt to contact you directly to resolve your concerns. If you have an unresolved privacy or data use concern that you feel we have not addressed satisfactorily, please contact our US-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

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