We value your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information you provide to us.

INTRODUCE

The use of our services may involve the collection and use of your Information (as defined in the “The Information We Collect and How We Collect It” section below) on our services (including all our mobile applications and respective websites). It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully. By using our services, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time. If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact us via email here.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies across all of our services as defined above. This Privacy Policy is incorporated into and forms part of the Battlecry User Agreement that you agree to in order to use our services. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the Battlecry User Agreement, unless otherwise defined in this Privacy Policy or the context requires otherwise. Please also note that this Privacy Policy does not apply to Information collected: (i) through third party services (including any third party websites) that you may access through our services; or (ii) by other companies and organizations who advertise their services on our services.

CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy. Where we consider that any changes to this Privacy Policy are reasonably material, we will notify you (via http://Battlecry, direct communication to you, or other means) prior to the change becoming effective. By continuing to use our services after any changes to this Privacy Policy, with or without notice from us, you are agreeing to the revised Privacy Policy.

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

In providing our services, we collect, store and use the following Information relating to you: “Information” is Personal Information and Non-Personal Information; “Personal Information” is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following: information you make available to us when you open an account or use our services, such as your name, telephone number and email address; information which you make available to our services as you use them, including Shared Information you make available to others through our services and information you store using our services; Shared Information that others using our services make available about you, such as information contained in posts they make and communications they make to you and others using our services; and information we collect as you use our services, such as certain Location Data and Log Data. “Location Data” s information that we collect regarding your location (when you use a location-enabled service), including: the location of your device when you use our services, such as from the GPS, WiFi, compass, accelerometer or other sensors in your mobile device; the IP address of the device or internet service you use to access our services, other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located and Shared Information you or others post indicating your location, such as any geotag information that is embedded in any photos you make available to us; and if you have provided us with your location data previously and would like us to delete such existing location data, you may be able to do so via our services. “Log Data” is technical information that is automatically collected by us when you use our services, whether through the use of cookies, web beacons and log files (as explained in more detail in the “Cookies, Web Beacons and Log Files” section below) or otherwise, including: technical information such as your mobile carrier, configuration information made available by your web browser or other programs you use to access our services, your IP address and your device’s version and identification number, information about what you have searched for and looked at while using our services, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using our services; information about communications you have made using our services, such as the people you’ve communicated with and the time, data and duration of your communications; and metadata, which means information related to items you have made available through our services, such as the date, time or location that a shared photograph or video was taken or posted. “Non-Personal Information” is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymized or pseudonymized form. “Shared Information” is information about you or relating to you that is voluntarily shared on our services, including postings that you make on our services (including your public profile, the lists you create), any postings from others that you re-post and including Location Data and Log Data associated with these postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.

HOW WE USE YOUR INFORMATION

We may use your Information for any of the following purposes: to provide our services to you; for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of our services; to provide you with advertising and direct marketing that is more relevant to you (as discussed in more detail below under the “Direct Marketing” section below); to better understand how you access and use our services, for the purposes of trying to improve our services and to respond to customer desires and preferences, including language and location customization, personalized help and instructions, or other responses to your and other customers’ usage of our services; to help us develop our new services and improve our existing services; to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with our services when your account is subscribed to an official account; and to allow you to participate in surveys about our products and services. If you participate in a survey, we may request certain personally identifiable information from you. Participation in these surveys is voluntary and you therefore have a choice whether or not to disclose this information. We use may use a third party service provider to conduct these surveys and such third party service provider will be prohibited from using your personally identifiable information for any other purpose. Please note that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where you have consented, Personal Information collected through our site or service may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualized manner). For example, Personal Information collected during your use of one of our services may be used to suggest particular content that can be made available to you on another service or be used to try to present more relevant advertising to you in another service. You may also from time to time ask us to migrate or export your Personal Information contained in one of our services to another of our services, where such migration option is available. If any of your Personal Information comprises Your Content (as defined in the Battlecry User Agreement), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the “Your Content” section of the Battlecry User Agreement. COOKIES, WEB BEACONS AND LOG FILES We may use cookies, web beacons and log files to collect, and store Information about you or relating to you. We further describe how we use cookies, log files and web beacons in our User Agreement.

SHARING OF YOUR PERSONAL INFORMATION

Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes. We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assists us and you with location data), in each case, for the purposes of: (i) providing our services to you; (ii) assisting us in carrying out the purposes set out under the “How We Use Your Information” section above; (iii) carrying out our obligations and enforcing our rights under the Battlecry User Agreement or this Privacy Policy; and/or (iv) help understand and improve our services. These third parties may be located, and use and store your Personal Information, outside of your jurisdiction for these purposes. Where we or our affiliate companies do share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement. You consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this section. These third parties will use Personal Information to provide services to us and for their own internal use, including analytics use. We allow third parties such as analytics providers and advertising partners to collect your Personal Information over time and across different websites or online services when you use our services. As we continue to develop our business, we or our affiliate companies may be acquired by a third party or re-organize our group structure. In these circumstances, it may be the case that your Information is transferred within our group and/or transferred to a third party who will continue to operate our services or similar services under either this Privacy Policy or a different privacy policy which will be notified to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your jurisdiction. You agree that we or our affiliate companies may be required to retain, preserve or disclose your Personal Information: (i) in order to comply with applicable laws or regulations; (ii) in order to comply with a court order, subpoena or other legal process; (iii) in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or (iv) where we believe it is reasonably necessary to comply with applicable laws or regulations. You also agree that we or our affiliate companies may need to disclose your Personal Information in order to enforce the Battlecry User Agreement or this Privacy Policy, protect our rights, property or safety, or the rights, property or safety of our affiliate companies or other users of our services.

A WORD ABOUT SHARED INFORMATION

Our service enables Shared Information to be shared publicly with all users of that service and not just your contacts. Our social media services in particular are primarily designed to help you share Shared Information with the world via features either provided by us or third parties, so Shared Information can be broadly and instantly transmitted and will remain public for as long as you do not delete it (and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us). Please consider carefully what you post and communicate through our services. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in some of our services. If you would like to update or amend your Personal Information you may do so by logging into your account and making the appropriate changes. To request removal of your Personal Information from our services, or to request the removal of an unauthorized account, please contact us. In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so.

COMMUNICATIONS FROM US

Newsletters and other types of communications. When you use our service, we may use your Information to send you emails, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting us via our website. Service-related announcements We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

A WORD ABOUT SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterized as “sensitive” and is subject to stricter regulation than other personal information. Please note that content and information that you input to our services, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others. We urge you to consider whether it is appropriate to communicate Personal Information of a sensitive nature in the manner you are proposing to communicate it using our services. You consent to all processing of sensitive Personal Information for the purposes and in the manner described in this Privacy Policy. Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.

THIRD PARTY SERVICES ON OUR SERVICES

Our service may link you to, social media or other services (including websites) provided by a third party. For example: you may be able to share content on, or login to, our services using services provided by third parties. The third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer to enable such feature to function properly; and we may (whether in advertisements or otherwise within our services) provide you with links that allow you to access third party services or websites. These third party social media or other services may be hosted by the relevant third party or us. Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties, are subject to the relevant third party’s own terms of services and privacy policies and not the Battlecry User Agreement or this Privacy Policy, so please review their terms carefully. This Privacy Policy only applies to any Information collected by us, does not apply to any services offered by or information practices of any third parties, and we bear no liability for any third party use of any Information provided by you to them.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction. You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy. We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of Information. In our service, we will use encryption technology (such as SSL) to protect certain sensitive Information (such as location data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact us.

PERIOD OF USE OF YOUR PERSONAL INFORMATION

Subject to applicable laws and regulations (including as set out under the “Sharing of your Personal Information” section above), we will only use your Personal Information for so long as is necessary to fulfil the purposes as set out under the “How We Use Your Information” section above. Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to us, or where we offer this option in our services, you may also log into your account with us and make the appropriate changes. We will respond to all requests made under this “Retention of your Personal Information” section within 60 days. Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through our services, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using our services may put your Personal Information in the hands of third parties that we cannot control.