PRIVACY POLICY

 

Introduction

Fifth Column Games Inc. and its related entities (collectively "Fifth Column", "us", "our" or "we") is dedicated to protecting the privacy rights of our users ("users" or "you"). This Privacy Policy describes the ways we collect, store, use, and manage the information you provide in connection with our website at www.c5games.com (the "Site") or any Fifth Column game or application provided on other websites or other third party sources (collectively, the "Service"). Please note that the scope of this Privacy Policy is limited to information collected by Fifth Column through your use of the Service.

What Information Is Collected

Fifth Column’s primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service. Fifth Column may use user information to analyze user behavior in Fifth Column’s games. For example, Fifth Column may analyze user information to determine how often a user plays a particular game, if a user purchases premium goods and other similar events.

When you use any of the Fifth Column games or applications, we may collect and record information through the social networking website you use to access the Service ("SN Website") or other third party source in accordance with the policies and terms of the SN Website or service provider. We may share such information with the SN Website for its use as permitted by the terms of your agreement and privacy settings with the SN Website.

We may collect both Personal and Non-Personal Information. Personal Information is defined as information about you that can be used to contact or identify you such as your name, email address, home address, and phone number. Personal Information does not include aggregate information, which is data we collect about the characteristics and activities of users of the Service, from which any Personal Information has been removed. Non-Personal Information does not identify you personally and can include age, gender or interests. We may combine Personal Information with Non-Personal Information and use this combination to improve your experience or to aggregate it with information collected from other users to improve or analyze our Service. This privacy policy in no way limits or restricts our collection of aggregate information or of Non-Personal Information.

The information we collect when you access the Service on an SN Website may include information that is visible on your social networking page such as: (1) your name, (2) SN Website user identification number and/or name, (3) locale, city, state and country, (4) sex, (5) birthdate, (6) time zone and (7) email address. We may also collect your email address directly from you when you access our Service. If you provide your email address in connection with a Fifth Column game, the email address will be retained by Fifth Column and we may use that email address to contact you about other Fifth Column games.

When you visit our Site or use the Service on an SN Website, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring Web site addresses are logged automatically. We also collect information about your usage and activity, such as number of clicks, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity. We use this information to monitor and analyze use of the Services.

We may also acquire information from you through (1) your access and participation in message boards on the Service, (2) your email of a question to our customer support, (3) your purchase of a virtual product of any type, (4) your participation in surveys regarding the Service or (5) your participation in a sweepstakes or contest through the Service. Please note that because third parties manage the purchases of virtual goods offered by the Service, we do not have access to your credit card details and billing information.

If you launch any of our games or applications on a mobile device, we may also collect information regarding your device type, iOS advertising identifiers, HTML cookies, Open UDID, referral URL, operating system and version, IP address and unique device ID (UDID). If you sign into the Service on your mobile device with Facebook Connect we may collect information that is visible via your Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook friends. This information will be primarily used for social features.

If you provide your email address in connection with a Fifth Column game, the email address may be retained by Fifth Column and we may use that email address to contact you about your gaming experience. We may also use part of your email address for friend-to-friend interaction.

How We Use Your Personal Information

We use your personal information for the following purposes:

  1. To provide and operate our Service:
    • To create user accounts/profiles to enable you to play our Games
    • To provide you with the correct versions of our games and/or applications (e.g. knowing which language to make our games available to you in)
    • To enable you to communicate with other users (including via chat rooms, forums and/or private messages) and leaderboards local to you
    • To send you service-related communications including confirmations, technical notices, updates, security alerts, and support/administrative messages
  2. To improve our Service and keep them secure:
    • To respond to your customer support requests (e.g. if you write to us with a complaint)
    • To receive error messages about any issues you/your device encounters with our Service to enable us to fix bugs and interoperability issues
    • To detect and prevent illegal activities (e.g. hacking or cheating)
    • To track game installs (for purposes of measuring the effectiveness of marketing campaigns)
    • To conduct optional user feedback surveys
    • To understand you, your preferences and user traffic to enhance your experience and enjoyment using our Service
    • To conduct research
  3. To personalize our Service: ·
    • To remember you next time you visit our Service
    • Communicate with you about promotions, rewards, upcoming events, and other news about products and services we offer
  4. For promotional activities (including marketing and advertising)
    • To provide you with in-game offers and rewards based on your in-game behaviors
    • To serve you with relevant targeted advertisements (necessary to fund our Services)
    • To make you offers to purchase in-game items on discount based on your in-game activity and purchase history.
    • To send you marketing communications and/or newsletters about rewards and promotions if you have subscribed to them
  5. Other
    • To comply with our legal obligations
    • To exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person
    • To prevent and/or detect fraud or fraudulent behavior

Sharing Your Personal Information With Third Parties

Unless otherwise specified in this Privacy Policy or unless legally required to do so, Fifth Column will not sell, rent or otherwise disclose your Personal Information to any outside company or organization. This Privacy Policy excludes data that may be stored or transmitted to or from the service provider hosting the Websites.

In addition to those uses set forth above, Fifth Column may hire companies to help provide products or services, like a shipping company that may deliver packages, a financial partner that assists in the completion of transactions you request or any other third party that is needed to assist in the completion of transactions you request. In those instances, there is a need to share your information with these third parties. Fifth Column may also work with other companies who help either to gather your information or to communicate with you. Your opt-out of receiving information from us and/or third parties will not apply to sharing by Fifth Column of your information with any of these third parties. Nonetheless, except as separately permitted by other provisions of this Privacy Policy, these third parties are allowed to gather, receive and use your information only for the purposes described herein or as required by law.

Fifth Column may make bulletin boards, chat rooms, job listing areas, message boards, newsgroups and other community services available to you on the Websites. Please understand that any information that is disclosed by you in these areas becomes public information. When you disclose such information in a bulletin board, message board, chat room, blog or any other public forum, you do so at your own risk. Fifth Column has no control over its use and you should exercise caution when deciding to disclose your Personal Information or any other information about yourself. The information presented in these areas reflects the views of the individual users or hosts and does not necessarily reflect the views of Fifth Column. Fifth Column reserves the right (but has no obligation) to monitor the use of bulletin boards, message boards, chat rooms, blogs or other public forums on the Websites.

Fifth Column may also disclose your Personal Information if:

  1. Your information is subject to disclosure in response to judicial or governmental subpoenas, warrants or orders served on Fifth Column;
  2. Your information is subject to disclosure to protect Fifth Column’s rights or property, to enforce the provisions of this Privacy Policy and/or Fifth Column Terms of Use and/or to prevent harm to yourself or to another; or
  3. Your information is subject to disclosure or transfer if Fifth Column or its business is sold or offered for sale to another entity or individual(s), a petition for relief is filed under U.S. Bankruptcy laws for or against Fifth Column or if Fifth Column becomes subject to an order of appointment of a trustee or receiver.

Fifth Column reserves the right to release and/or use all information contained within our databases, access logs or other records concerning you if you violate this Privacy Policy, our Terms of Use or other rules, policies, notices, agreements or guidelines, or if you intentionally or unintentionally partake (or are reasonably suspected of partaking) in any illegal activity, including but not limited to hacking, even without a subpoena, warrant or other court order, and to release such information in response to court and governmental orders, civil subpoenas, discovery requests and as otherwise required by law and/or to initiate our own legal proceedings. Fifth Column cooperates with law enforcement agencies in identifying those who may be using the Websites (or any part thereof) for illegal activities. Fifth Column also reserves the right to report any suspected illegal activity to law enforcement individuals or to entities for investigation or prosecution.

Fifth Column may purchase a business or sell one or more of our businesses and your Personal Information may be transferred as a part of the purchase or sale. In the event that we purchase a business, the Personal Information received with that business would be treated in accordance with this Privacy Policy, if it is practicable and permissible to do so. In the event that we sell a business, we will attempt to include provisions in the selling contract requiring the purchaser to treat your Personal Information in the same manner required by this Privacy Policy. Thus, any of your opt-out requests will not affect our right to transfer your information to a purchaser in these circumstances. Fifth Column also reserves the right to transfer your Personal Information to a third party in the event of a transfer of all or substantially all of Fifth Column’s assets to a third party, provided that the third party agrees to adhere to the terms of this Privacy Policy.

Fifth Column may take your Personal Information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, there are no restrictions under this Privacy Policy upon the right of Fifth Column to aggregate or de-personalize your personal information, and Fifth Column may use and/or share with third parties the resulting non-personally identifiable information in any manner in Fifth Column’s sole discretion.

We may share your information, including personal information, with third parties or allow third parties to collect this information from our Services in the following circumstances:

Friends and Other Fifth Column Games Players

Fifth Column’s games and Services support and often encourage you to interact with other players. In most Fifth Column's games, if you play through a social network or connect to a social network (for example, Facebook), your social network friends who also play a Fifth Column game will see your name, photo, player profile (which may include the information described above in Information Collected and Used), and descriptions of your in-game activity.

In-game Advertisements

We use advertising to enable us to offer some of our games, game features, and other Services for free. These advertisements may include, without limitation, banner ads on game boards or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer to provide virtual currency or other in-game items to players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, completing a survey, or finishing a particular game level. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Fifth Column Games.

We may share some of your information with advertisers to tailor the advertisements you see when you use our Service to your interests and to enable us to offer our Service for free.

We do not actively share personal information that directly identifies you with third-party advertisers for their direct marketing purposes unless you give us your consent.

To enable advertisers, ad networks, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Service:

  • performance data (like the number of clicks on an advertisement);
  • certain technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
  • a unique identifier, such as your social network ID; and/or
  • other contextual data about your game play (like your level and session length).

In addition to serving you with relevant ads, the information collected may be used to:

  • measure how effective ads are;
  • offer you targeted advertising (both on and off our Service) 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 interest-based advertising or behavioral advertising); and/or
  • undertake web analytics to analyze traffic and other player activity to improve your experience.

Advertisers or ad networks may collect this information through the use of cookies and other similar tracking technologies, and they may use a single tracking technology or multiple tracking technologies at the same time.

If you do not want to receive tailored in-application advertisements from third parties, please contact us at contact@c5games.com.

Opt-out Preferences

Opt-out. You may contact us anytime via e-mail to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; or (iv) any new processing of your personal data that we may carry out beyond the original purpose. Please note that your use of some of the Site or Game may be ineffective upon opt-out.

Access. You may access the data we hold about you at any time by contacting us directly.

Amend. You can also contact us to update or correct any inaccuracies in your personal data.

Move. Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.

Erase and forget. In certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

You may contact us at contact@c5games.com anytime for any other questions you may have about your personal data and our use of such personal data.

Third Party Websites

If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

California Privacy Rights

Fifth Column does not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by "opting in" to receive information from a third party that is participating in a sweepstakes or other promotion on one of our sites. If you do ask Fifth Column to share your personal information with a third party for its marketing purposes, Fifth Column will only share information in connection with that specific promotion, as Fifth Column does not share information with any third party (other than our service providers) on a continual basis. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt in to such use when you provide personal information on one of our sites.

Security

We have put in place reasonable technical and organizational measures designed to secure your information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your information for improper purposes.

Policy Regarding Children

The Service is not geared toward children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13. If we learn that a child under 13 has provided us with Personal Information we will delete such information from our files.

Governing Law

Our Websites are controlled and operated from our offices within the State of California, United States of America. By choosing to visit our Websites or otherwise provide information to Fifth Column, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of California as more fully set forth in our Terms of Use.

If you are accessing our Websites from any location with regulations or laws governing personal data collection, use or disclosure that differ from United States laws or regulations, please note that through your continued use of our Websites, which is governed by the laws of the State of California and the United States of America and this Privacy Policy, you are transferring Personal Information to the United States of America and you consent to that transfer and any associated processing.

Contact Us

If you have any questions concerning this privacy policy please contact us at contact@c5games.com

Last Updated: October 27, 2018