Effective date: June 23rd, 2019
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data. Please read our GDPR Privacy Notice for more information.
What information does Three Swords collect?
Information You Provide to Us:
We receive and store any information you knowingly provide to us. For example, if you email us at firstname.lastname@example.org, we may collect Personal Information that you provide to us in connection with such email communication (such as email address and name). Note, however, that while we will receive your email address if you email us at email@example.com, you do not need to provide your first or last name or any other Personal Information when you contact us, and we will not store your Personal Information for longer than required to address your issues or concerns.
We may also collect Personal Information that you choose to provide through any voluntary surveys that we may send through the App about your experience with our Services, including gender and age. Providing your email address to us through these surveys is optional. We use information from these surveys to improve your experience with the App.
Information Collected Automatically:
Whenever you interact with our Website or App, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, device identification, advertising identifiers (such as IDFAs/IDFVs), “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and “remember” your browser during subsequent visits for purposes of functionality, preferences, and website performance. They also tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies as follows:
For iOS: Every iOS includes an advertising identifier (IDFA) with two key features:
- Users can reset the identifier at any time.
- Users can also opt out of all remarketing campaigns by activating the Limit Ad Tracking (LAT) setting, thus keeping advertisers from using the device’s IDFA for behavioral advertising. For more information about how to enable this setting, click here.
For Android: Every Android device includes an advertising identifier (AAID). To opt out or to change its settings, follow these steps:
- If using Android 2.3 or above, select “Google settings” in the app drawer.
- Select “Ads”.
- Select “Reset advertising ID” to generate a new identifier and eliminate any previously stored data.
- Then select “Opt out of interest-based ads”.
We may use data that we collect automatically from you to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Where is my Personal Information stored and processed?
Your Personal Information will be stored and processed in the EU and in the United States. We comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the European Union to the United States. We have certified to the Department of Commerce that we adhere to the seven Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability, in relation to any Personal Information that we receive from within the European Union (the “Privacy Shield Principles”). Principle 7, the recourse, enforcement and liability principle, provides that we remain potentially liable if a third party processing Personal Information received from the European Union on our behalf processes that Personal Information in a manner that is inconsistent with the Privacy Shield Principles (unless we can prove that we are not responsible for the event giving rise to the damage). We are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to any failure to comply with the Privacy Shield Principles.
What if I have questions, concerns or complaints?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to firstname.lastname@example.org. We will make every effort to resolve your concerns.
In compliance with the Privacy Shield Principles specified above (where applicable), we commit to resolve complaints about your privacy and our collection or use of your Personal Information. We have further committed to refer unresolved Privacy Shield complaints to JAMS, Inc. (“JAMS”), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may contact or visit JAMS by visiting www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for residual claims about whether we have violated our obligations to you under the Privacy Shield, and if that violation remains fully or partially un-remedied.
Will Three Swords share any of the Personal Information it receives?
We may share your Personal Information with third parties as described below:
Advertisers: We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.
We may also deliver a file to you through the Website (known as a “web beacon” or “pixel tag”) from third parties (e.g., Facebook). Web beacons allow third parties to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site. You may be able to opt-out of web beacon tracking conducted by third parties through our Services by adjusting the Do Not Track settings on your browser; please note that we don’t control whether or how these third parties comply with Do Not Track requests.
Affiliated Businesses: We occasionally partner with third parties that offer applications that you may also be interested in using. We will advertise any such applications through the App, but you have a choice as to whether to download and use those applications. If you choose to download any third-party applications, we will share your Personal Information (e.g., IDFAs) with that third party only to the extent that it is necessary for you to use the third-party application and to measure the effectiveness of the joint advertising campaign. We have no control over the policies and practices of third parties as to privacy or anything else, so if you choose to download and use any third-party applications, please review all relevant terms and policies posted by those third parties.
Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we use third parties for customer support functions, hosting services, mobile ad mediation services, ad networks, and analytics services. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Please click here for a list of vendors, third-party service providers and agents who provide us services and with whom we share Personal Information.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Is Personal Information about me secure?
A fundamental principle of data protection and security at Three Swords is to store only the types of Personal Information about a user that are deemed necessary and will be used with high frequency. Personal Information that is no longer needed is removed from our servers. This narrows the breadth of protection of Personal Information quite significantly as we store very little Personal Information about our users that necessitates protection. That being said, while we store as little Personal Information as possible, unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of Personal Information at any time.
In order to protect your Personal Information, we have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All Personal Information you provide to us is stored on our secure servers behind firewalls. All transactions, regardless of their nature, are encrypted using industry standard SSL technology.
What Personal Information can I access?
All individuals have the right to access the data we have about them. We will take reasonable steps to enable individuals, either directly or in connection with Partners, to correct, amend, or delete personal data that is demonstrated to be inaccurate. If you have any questions about viewing or updating the information we have on file about you, please contact us at email@example.com.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to firstname.lastname@example.org.
What choices do I have?
You can use many of the features of the Services without registering, thereby limiting the type of information that we collect.
You can always opt not to disclose information to us, but keep in mind some information may be needed to take advantage of some of our features.
If you delete the App, some information may remain in our records after your deletion. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to email@example.com, and we will try to resolve your concerns.
Contact: You may contact us at the following address: Niska 6, 11250 Belgrade, Serbia