TRCS Inc Privacy Policy
TRCS Inc - Privacy Policy
Last updated: 11 August 2011
TRCS Inc (“TRCS”), and its subsidiaries respect the privacy rights
of our users and are committed to protecting the information
collected through its online products, online services and websites
including, but not limited to TRCS's SudokuShared™ games (together
“Services”). TRCS has adopted this privacy policy (“Privacy Policy”)
to explain how TRCS collects, stores, and uses the information
collected in connection with TRCS's Services.
Should you have any questions relating to this Privacy Policy,
please contact us at privacy@trcs.com or alternatively at TRCS Inc,
Legal Department, 8170 Estes Circle, Arvada CO 80005.
BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE
SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND
INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA IN
ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS
PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE
ACCESS THE SERVICES. TRCS reserves the right to modify this Privacy
Policy at reasonable times, so please review it frequently. If TRCS
makes material or significant changes to this Privacy Policy, TRCS
will post a notice on TRCS’s website along with the updated Privacy
Policy. Your continued use of Services will signify your acceptance
of the changes to this Privacy Policy.
Non-personal data:
For purposes of this Privacy Policy, “non-personal data” means
information that does not directly identify you. Additionally,
non-personal data means “aggregate” and “de-personalized”
information, which is data TRCS collects about the use of TRCS
Services, from which any personally identifiable data has been
removed.
TRCS may use tools or third party analytical software to
automatically collect and use certain non-personal data that does
not directly enable TRCS to identify you. The types of non-personal
data TRCS may collect and use include, but are not limited to: (i)
device properties, including, but not limited to unique device
identifier or other device identifier ("UDID"); (ii) device software
platform and firmware; (iii) mobile phone carrier; (iv) geographical
data such as zip code, area code and location; (v) game score and
achievements; (vi) other non-personal data as reasonably required by
TRCS to enhance the Services and other TRCS products and services.
TRCS may use and disclose to TRCS’s partners and contractors the
collected non-personal data for purposes of analyzing usage of the
Services, advertisement serving, managing and providing the Services
and to further develop the Services and other TRCS services and
products.
You recognize and agree that the analytics companies utilized by
TRCS may combine the information collected with other information
they have independently collected from other services or products
relating to your activities. These companies collect and use
information under their own privacy policies.
Ad Serving Technology:
TRCS reserves the right to use and disclose the collected
non-personal data for purposes of advertisement by TRCS or TRCS’s
partners and contractors. TRCS may employ third party ad serving
technologies that use certain methods to collect information as a
result of ad serving through Services. TRCS or third parties
operating the ad serving technology may use demographic and location
information as well as information logged from your hardware or
device to ensure that appropriate advertising is presented within
the Service. TRCS or third parties may collect and use data for this
purpose including, but not limited to IP address (including for
purposes of determining your approximate geographic location), UDID,
software, applications, hardware, browser information, internet and
on-line usage information and in-game information. The foregoing
data may be used and disclosed in accordance with this Privacy
Policy and the privacy policy of the company providing the ad
serving technology.
You recognize and agree that the advertising companies who deliver
ads for TRCS may combine the information collected with other
information they have independently collected from other services or
products. These companies collect and use information under their
own privacy policies. These ad serving technologies are integrated
into Services; if you do not want to be subject to this technology,
do not use or access Services. Although TRCS takes commercially
reasonable steps to instruct such advertising companies to comply
with the terms and conditions of this Privacy Policy, TRCS does not
have access to or control of third party technologies.
Personal Data:
For purposes of this Privacy Policy, “personal data” means
personally identifiable information that specifically identifies you
as an individual.
Likely situations when you make personal data available to TRCS
include, but are not limited to: (i) registration for Services,
contests and special events; (ii) accessing Services using a third
party ID, such as social networking sites or gaming services; (iii)
subscribing to newsletters; (iv) purchasing a product or services
through TRCS’s online stores; (v) using “invite,” "subscribe," or
other similar features; (vi) requesting technical support; and (vii)
otherwise through use of TRCS Services where personal data is
required for use and/or participation.
The types of personal data may vary depending on the type of
activity you are engaged in. The personal data TRCS may collect and
process may include, but are not limited to your name, screen/nick
name, TRCS Services’ or third party service ID, e-mail address,
phone number, photo or other image, birthdate, sex, address, friend
connections, avatar image, credit card information, shipping
information; and location (only if directly identifiable to you,
otherwise we treat location as non-personal data).
TRCS may use collected personal data for purposes of analyzing usage
of the Services, providing customer and technical support, managing
and providing Services (including managing advertisement serving)
and to further develop the Services and other TRCS services and
products. TRCS may combine non-personal data with personal data.
Please note that certain features of the Services may be able to
connect to your social networking sites to obtain additional
information about you. In such cases, TRCS may be able to collect
certain information from your social networking profile when your
social networking site permits it, and when you consent to allow
your social networking site to make that information available to
TRCS. This information may include, but is not limited to, your
name, profile picture, gender, user ID, email address, your country,
your language, your time zone, the organizations and links on your
profile page, the names and profile pictures of your social
networking site “friends” and other information you have included in
your social networking site profile. TRCS may associate and/or
combine as well as use information collected by TRCS and/or obtained
through such social networking sites in accordance with this Privacy
Policy.
Disclosure and Transfer of Personal Data:
TRCS collects and processes personal data on a voluntary basis and
it is not in the business of selling your personal data to third
parties. Personal data may, however, occasionally be disclosed in
accordance with applicable legislation and this Privacy Policy.
Additionally, TRCS may disclose personal data to its subsidiaries in
accordance with this Privacy Policy.
TRCS may hire agents and contractors to collect and process personal
data on TRCS’s behalf and in such cases such agents and contractors
will be instructed to comply with our Privacy Policy and to use
personal data only for the purposes for which the third party has
been engaged by TRCS. These agents and contractors may not use your
personal data for their own marketing purposes. TRCS may use third
party service providers such as credit card processors, e-mail
service providers, shipping agents, data analyzers and business
intelligence providers. TRCS has the right to share your personal
data as necessary for the aforementioned third parties to provide
their services for TRCS. TRCS is not liable for the acts and
omissions of these third parties, except as provided by mandatory
law.
TRCS may disclose your personal data to third parties as required by
law enforcement or other government officials in connection with an
investigation of fraud, intellectual property infringements, or
other activity that is illegal or may expose you or TRCS to legal
liability. TRCS may also disclose your personal data to third
parties when TRCS has a reason to believe that a disclosure is
necessary to address potential or actual injury or interference with
TRCS’s rights, property, operations, users or others who may be
harmed or may suffer loss or damage, or TRCS believes that such
disclosure is necessary to protect TRCS’s rights, combat fraud
and/or comply with a judicial proceeding, court order, or legal
process served on TRCS.
Data Retention and Correctness:
TRCS retains the data collected pursuant to this Privacy Policy for
the period necessary to fulfill the purposes outlined in this
Privacy Policy unless a longer retention period is required or
permitted by law. Thereafter if the collected data is no longer
needed for purposes specified in this Privacy Policy, TRCS deletes
all aforementioned data in its possession. TRCS does not verify the
correctness of personal data.
Even if data is changed or deleted, TRCS may still retain some of
the data to resolve disputes, enforce TRCS user agreements, and
comply with technical and legal requirements and constraints related
to the security, integrity and operation of Services.
Cookies and beacons:
The Services may use “cookies” and other technologies such as pixel
tags, clear GIFs and web beacons. TRCS treats information collected
by cookies and similar technologies as non-personal data.
Third Party Terms and Conditions:
Please note that your access to and use of the Services may be
subject to certain third party terms and conditions and privacy
policies, including but not limited to application stores, mobile
software platforms, on-line gaming platforms, social networking
services and payment providers. You recognize and agree that TRCS is
not liable for any such third party terms and conditions and their
use of your personal data.
TRCS may in its discretion make available links through
advertisements or otherwise enabe you to access third party products
or services. Please note that, while using such products or
services, you are using products or services developed and
administered by people or companies not affiliated with or
controlled by TRCS. TRCS is not responsible for the actions of those
people or companies, the content of their products or services, the
use of information you provide to them, or any products or services
they may offer. The fact that TRCS is linking to those products or
services does not constitute our sponsorship of, or affiliation
with, those people or companies.
Please note that certain Services that TRCS may offer, such as
multiplayer gaming, social networking and gaming console services,
may use third party services to provide authentication for the
Services with a gaming console ID, social networking ID or gaming
network account. When you register to join or use the Services from
a third-party gaming or social networking system, certain personally
identifiable user and/or membership data may be transferred
automatically to and from TRCS and you hereby consent to the
processing, combining, disclosing and retaining of such data in
accordance with this Privacy Policy by TRCS.
Safeguards:
TRCS follows generally accepted industry standards and maintains
reasonable safeguards to attempt to ensure the security, integrity
and privacy of the information in TRCS’s possession. Only those
persons with a need to process your personal data in connection with
the fulfillment of their tasks in accordance with the purposes of
this Privacy Policy and for the purposes of performing technical
maintenance, have access to your personal data in TRCS’s possession.
Personal data collected by TRCS is stored in secure operating
environments that are not available to the public. To prevent
unauthorized on-line access to personal data, TRCS maintains
personal data behind a firewall-protected server. However, no system
can be 100% secure and there is the possibility that despite TRCS’s
reasonable efforts, there could be unauthorized access to your
personal data. By using the Services, you assume this risk.
Other:
Please be aware of the open nature of certain social networking and
other open features of the Services TRCS may make available to you.
You may choose to disclose data about yourself in the course of
contributing user generated content to the Services. Any Data that
you disclose in any of these forums, blogs, chats or the like is
public information, and there is no expectation of privacy or
confidentiality. TRCS is not responsible for any personal data you
choose to make public in any of these forums.
If you are under 15 years of age or a minor in your country of
residence, please ask your legal guardian’s permission to use or
access the Services. TRCS takes children’s’ privacy seriously, and
encourages parents and/or guardians to play an active role in their
children's online experience at all times.
TRCS may store and/or transfer your personal data to its affiliates
and partners in and outside of EU/EEA member states and the United
States in accordance with mandatory legislation and this Privacy
Policy. In addition, in the event of a merger, acquisition,
reorganization, bankruptcy, or other similar event involving all or
a portion of TRCS, TRCS’s customer information may be transferred to
TRCS’s successor or assign.
Further information:
Should you wish opt-out from receiving communications (such as
newsletters or offers) from TRCS, please contact
unsubscribe@trcs.com.
TRCS makes good faith efforts to enable you to review, update,
correct or delete your personal data in TRCS’s possession. In order
to do so, please contact TRCS at privacy@trcs.com. TRCS will need
sufficient information from you to establish your identity and to
verify your access request, and also to assist us in handling your
request. Requests will be processed as soon as possible. Please note
that even if personal data is changed or deleted according to your
request, TRCS may still retain some of your personal data to resolve
disputes, enforce TRCS user agreement(s), and comply with technical
and legal requirements and constraints related to the security,
integrity and operation of TRCS Services.
TRCS regularly reviews its compliance with this Privacy Policy. If
TRCS receives a formal written complaint from you, it is TRCS’s
policy to attempt to contact you directly to address any of your
concerns. TRCS will cooperate with the appropriate governmental
authorities, including data protection authorities, to resolve any
complaints regarding the collection, use, transfer or disclosure of
personal data that cannot be amicably resolved between you and TRCS.