Last updat­ed: 8 Feb 2013

Sirqul, Inc Pri­va­cy Pol­i­cy

Sirqul, Inc (“Sirqul ”) has adopt­ed this pri­va­cy pol­i­cy (“Pri­va­cy Pol­i­cy”) to explain how Sirqul col­lects, stores, and uses the infor­ma­tion col­lect­ed in con­nec­tion with Sirqul’s prod­ucts, ser­vices and web­sites includ­ing, but not lim­it­ed to Sirqul’s fam­i­ly of Doo­dle Games (“Doo­dle Drops”, “Piece Corps”, Doo­dle Triv­ia”, “Doo­dle Words”, “Stick­man Chat”, etc.) and Sirqul’s on-line web­sites (togeth­er “Ser­vices ”).

Should you have any ques­tions relat­ing to this Pri­va­cy Pol­i­cy, please con­tact us at privacy[@Sirqul.com or alter­na­tive­ly at Sirqul, Inc, Legal Depart­ment, 81 Vine Street, Suite 101, Seat­tle, WA, 98121.

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, USE AND DISCLOSURE 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. Sirqul reserves the right to mod­i­fy this Pri­va­cy Pol­i­cy at rea­son­able times, so please review it fre­quent­ly. Your con­tin­ued use of Ser­vices will sig­ni­fy your accep­tance of the changes to this Pri­va­cy Pol­i­cy.

1. 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 Sirqul col­lects about the use of Sirqul Ser­vices, from which any per­son­al­ly iden­ti­fi­able data has been removed.

Sirqul may use tools or third par­ty ana­lyt­i­cal soft­ware to auto­mat­i­cal­ly col­lect and use cer­tain non-per­son­al data that does not direct­ly enable Sirqul to iden­ti­fy you. The types of non-per­son­al data Sirqul may col­lect and use include, but are not lim­it­ed to: (i) device prop­er­ties, includ­ing, but not lim­it­ed to IP address, Media Access Con­trol (“MAC”) address and unique device iden­ti­fier (“UDID”) or oth­er per­sis­tent or non-per­sis­tent device iden­ti­fier (“Device ID”); (ii) device soft­ware plat­form and firmware; (iii) mobile phone car­ri­er; (iv) geo­graph­i­cal data such as zip code, area code and coarse loca­tion; (v) game pro­gress, time used play­ing, score and achieve­ments; (vi) oth­er non-per­son­al data as rea­son­ably required by Sirqul to enhance the Ser­vices and oth­er Sirqul prod­ucts and ser­vices.

Specif­i­cal­ly, Sirqul uses a method­ol­o­gy of encrypt­ing the UDID asso­ci­at­ed with apps updat­ed and/or upload­ed to the var­i­ous Appli­ca­tion stores after Jan­u­ary 1st, 2013 such that the actu­al UDID or Device ID asso­ci­at­ed with an actu­al device is only used to cre­ate this encrypt­ed string on the device. The encrypt­ed string is then used as a 1-way iden­ti­fier, which fur­ther safe­guards users from hav­ing their actu­al device iden­ti­fied by the UDID or Device ID.

Sirqul may use and dis­close to Sirqul’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 Sirqul ser­vices and prod­ucts.

You rec­og­nize and agree that the ana­lyt­ics com­pa­nies uti­lized by Sirqul 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.

Sirqul may sup­ple­ment your per­son­al and non-per­son­al data with data received from third par­ties in con­nec­tion with demo­graph­ic, adver­tise­ment, mar­ket and oth­er ana­lyt­ics sur­veys or ser­vices.

2. Ad Serv­ing Tech­nol­o­gy

Sirqul reserves the right to use and dis­close the col­lect­ed non-per­son­al data for pur­pos­es of adver­tise­ment by Sirqul or Sirqul’s part­ners and con­trac­tors. Sirqul may employ third par­ty ad serv­ing tech­nolo­gies that use cer­tain meth­ods to col­lect infor­ma­tion as a result of ad serv­ing through Ser­vices. Sirqul 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. Sirqul or third par­ties may col­lect and use data for this pur­pose includ­ing, but not lim­it­ed to IP address (includ­ing but not lim­it­ed to for pur­pos­es of deter­min­ing your coarse loca­tion), UDID, Device ID, MAC, 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 Sirqul 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 Sirqul takes com­mer­cial­ly rea­son­able steps to instruct such adver­tis­ing com­pa­nies to com­ply with the terms and con­di­tions of this Pri­va­cy Pol­i­cy, Sirqul does not have access to or con­trol of third par­ty tech­nolo­gies.

Sirqul may dis­play to you behav­ioral­ly tar­get­ed adver­tis­ing. If you wish to “opt out” of cer­tain tar­get­ed adver­tis­ing, please vis­it http://www.youradchoices.com and/or www.networkadvertising.org. Please note that the links above may not reach all Sirqul ‘s adver­tis­ing part­ners and cer­tain behav­ioral­ly tar­get­ed adver­tis­ing may still be dis­played to you. If you want to be cer­tain that no behav­ioral­ly tar­get­ed adver­tise­ments are not dis­played to you, please do not use or access the Ser­vices. Addi­tion­al­ly please note that if you “opt out” it does not mean that you will no longer receive adver­tis­ing. It just means that the adver­tis­ing you see dis­played will not be cus­tomized to you and your inter­ests and may be less rel­e­vant to you.

3. Loca­tion Data

To the extent Sirqul makes loca­tion enabled Ser­vices avail­able and you use such Ser­vices, Sirqul may col­lect and process your loca­tion data to provide loca­tion relat­ed Ser­vices and adver­tise­ments. For exam­ple, some add-ons or offers may be avail­able at ded­i­cat­ed loca­tions. Sirqul may use var­i­ous tech­nolo­gies to deter­mine loca­tion, such as GPS, Wi-Fi or oth­er net­work-based data such as IP address. Your GPS geo-loca­tion is not accessed with­out your con­sent. Notwith­stand­ing Sirqul ‘s part­ners who are pro­vid­ing loca­tion relat­ed parts of the Ser­vice, Sirqul will not share your GPS geo-loca­tion with third par­ties with­out your con­sent. To the extent Sirqul makes avail­able GPS geo-loca­tion to third par­ties in accor­dance with this Pri­va­cy Pol­i­cy, it will be pro­vid­ed anony­mous­ly. Please note that Sirqul may share your anony­mous coarse loca­tion with its part­ners.

4. 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 Sirqul 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 Sirqul ‘s online stores; (v) using “tell a friend,” “email this page,” or oth­er sim­i­lar fea­tures; (vi) request­ing tech­ni­cal sup­port; and (vii) oth­er­wise through use of Sirqul 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 Sirqul may col­lect, process and use may include, but are not lim­it­ed to your name, screen/nick name, Sirqul 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 Sirqul treats loca­tion as non-per­son­al data).

If you choose to use Sirqul’s “tell a friend”, “share”, or a sim­i­lar ser­vice about Sirqul Ser­vices, Sirqul may store your friend’s name and con­tact details that you provide to Sirqul .

Sirqul may use per­son­al and non-per­son­al data, both indi­vid­u­al­ly and com­bined togeth­er, for pur­pos­es of ana­lyz­ing usage of the Ser­vices, pro­vid­ing cus­tomer and tech­ni­cal sup­port, man­ag­ing and pro­vid­ing Ser­vices (includ­ing man­ag­ing adver­tise­ment serv­ing), cus­tomiz­ing Sirqul’s com­mu­ni­ca­tions and to fur­ther devel­op the Ser­vices and oth­er Sirqul ser­vices and prod­ucts. Sirqul may com­bine non-per­son­al data with per­son­al data.

Sirqul may use your per­son­al data to send mes­sages to you with infor­ma­tive and/or com­mer­cial con­tent about Sirqul’s ser­vices or third par­ty prod­ucts and ser­vices Sirqul thinks may be of inter­est to you, such as new fea­tures and ser­vices, spe­cial offers and updat­ed infor­ma­tion.

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, Sirqul 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 Sirqul. 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. Sirqul may asso­ciate and/or com­bine as well as use infor­ma­tion col­lect­ed by Sirqul and/or obtained through such social net­work­ing sites in accor­dance with this Pri­va­cy Pol­i­cy.

5. Dis­clo­sure and Trans­fer of Per­son­al Data

Per­son­al data may be dis­closed in accor­dance with applic­a­ble leg­is­la­tion and this Pri­va­cy Pol­i­cy. Addi­tion­al­ly, Sirqul may dis­close per­son­al data to its par­ent com­pa­nies and its sub­sidiaries in accor­dance with this Pri­va­cy Pol­i­cy.

Sirqul may hire agents and con­trac­tors to col­lect and process per­son­al data on Sirqul’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 Sirqul. The­se agents and con­trac­tors may not use your per­son­al data for their own mar­ket­ing pur­pos­es. Sirqul may use third par­ty ser­vice providers such as cred­it card proces­sors, e-mail ser­vice providers, ship­ping agents, data ana­lyz­ers and busi­ness intel­li­gence providers. Sirqul has the right to share your per­son­al data as nec­es­sary for the afore­men­tioned third par­ties to provide their ser­vices for Sirqul. Sirqul is not liable for the acts and omis­sions of the­se third par­ties, except as pro­vid­ed by manda­to­ry law.

Sirqul 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 Sirqul to legal lia­bil­i­ty. Sirqul may also dis­close your per­son­al data to third par­ties when Sirqul has a rea­son to believe that a dis­clo­sure is nec­es­sary to address poten­tial or actu­al injury or inter­fer­ence with Sirqul’s rights, prop­er­ty, oper­a­tions, users or oth­ers who may be harmed or may suf­fer loss or dam­age, or Sirqul believes that such dis­clo­sure is nec­es­sary to pro­tect Sirqul’s rights, com­bat fraud and/or com­ply with a judi­cial pro­ceed­ing, court order, or legal process served on Sirqul . To the extent per­mit­ted by applic­a­ble law, Sirqul will make rea­son­able efforts to noti­fy you of such dis­clo­sure through Sirqul’s web­site or in anoth­er rea­son­able man­ner.

6. Data Reten­tion and Cor­rect­ness

Sirqul 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, Sirqul deletes all afore­men­tioned data in its pos­ses­sion with­in a rea­son­able time­frame. Sirqul does not ver­i­fy the cor­rect­ness of per­son­al data.

Irre­spec­tive of the above, Sirqul may still retain some of the data to the extent such reten­tion is nec­es­sary to resolve dis­putes, enforce Sirqul user agree­ments, and com­ply with tech­ni­cal and legal require­ments and con­straints relat­ed to the secu­ri­ty, integri­ty and oper­a­tion of Ser­vices.

7. Cook­ies, bea­cons and track­ing

The Ser­vices may use “cook­ies” and oth­er tech­nolo­gies such as pix­el tags, local­ly shared objects, clear GIFs and web bea­cons. Sirqul treats infor­ma­tion col­lect­ed by cook­ies and sim­i­lar tech­nolo­gies as non-per­son­al data.

Cook­ies: A “cook­ie” is a small bit of record-keep­ing infor­ma­tion that web­sites often store on a user’s com­put­er. Sirqul’s cook­ies do not include per­son­al data and are typ­i­cal­ly used to quick­ly iden­ti­fy your device and to “remem­ber” you. You can dis­able cook­ies or set your browser to alert you when cook­ies are being sent to your device; how­ev­er, dis­abling cook­ies may affect your abil­i­ty to use the Ser­vices.

Flash cook­ies & HTML5: Sirqul may also use HTML5 stor­age (local­ly stored objects). Local­ly shared objects are small files sim­i­lar to browser cook­ies and are used to remem­ber your set­tings to per­son­al­ize the look and feel of the Ser­vices. Local­ly shared objects only col­lect data in the aggre­gate. You may pre­vent local­ly shared objects from being placed by dis­abling local­ly stored objects in your browser. Local­ly stored objects, such as HTML5 Web Stor­age, are used for sim­i­lar pur­pos­es as cook­ies but typ­i­cal­ly may con­tain a greater amount and dif­fer­ent types of data than browser cook­ies.

Web Bea­cons and pix­el tags: A “web bea­con” or a “pix­el tag” is an elec­tron­ic image that allows Sirqul to count users who have vis­it­ed cer­tain pages or viewed cer­tain adver­tise­ments. Web bea­cons, like cook­ies, do not include per­son­al data. E-mails and oth­er elec­tron­ic com­mu­ni­ca­tions Sirqul sends to you may con­tain pix­el tags that enable Sirqul to track your usage of the com­mu­ni­ca­tion, includ­ing whether the com­mu­ni­ca­tion was opened and/or what links were fol­lowed, if any.

8. 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, map data providers, mobile soft­ware plat­forms, on-line gam­ing plat­forms, social net­work­ing ser­vices and pay­ment providers. You rec­og­nize and agree that Sirqul is not liable for any such third par­ty terms and con­di­tions and their use of your per­son­al data.

Sirqul may in its dis­cre­tion make avail­able links through adver­tise­ments or oth­er­wise enable 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 Sirqul . Sirqul 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 Sirqul is link­ing to those prod­ucts or ser­vices does not con­sti­tute our spon­sor­ship of, or affil­i­a­tion with, those peo­ple or com­pa­nies.

Sirqul may from time to time make avail­able Sirqul’s part­ners’ ser­vices, such as sweep­stakes or polls and such ser­vices may require you to dis­close per­son­al data in order to reg­is­ter for and access such ser­vices. Such ser­vices will rea­son­ably iden­ti­fy the part­ners at the point of where you are required to dis­close per­son­al data. If you at that point choose to dis­close your per­son­al data, such per­son­al data may be trans­ferred direct­ly or via Sirqul to such third par­ties and will be sub­ject to the pri­va­cy pol­i­cy and prac­tices of such third par­ties. Sirqul is not respon­si­ble for the pri­va­cy prac­tices and poli­cies of such third par­ties and, there­fore, you should review the pri­va­cy prac­tices and poli­cies of such third par­ties pri­or dis­clos­ing any per­son­al data in rela­tion to such ser­vices.

Please note that cer­tain Ser­vices that Sirqul 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 Sirqul and you here­by con­sent to the pro­cess­ing, using, com­bin­ing, dis­clos­ing and retain­ing of such data in accor­dance with this Pri­va­cy Pol­i­cy by Sirqul.

9. Safe­guards

Sirqul fol­lows gen­er­al­ly accept­ed indus­try stan­dards and main­tains rea­son­able safe­guards to attempt to ensure the secu­ri­ty, integri­ty and pri­va­cy of the infor­ma­tion in Sirqul’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 Sirqul ‘s pos­ses­sion. Per­son­al data col­lect­ed by Sirqul is stored in secure oper­at­ing envi­ron­ments that are not avail­able to the pub­lic. To pre­vent unau­tho­rized on-line access to per­son­al data, Sirqul main­tains per­son­al data behind a fire­wall-pro­tect­ed server. How­ev­er, no sys­tem can be 100% secure and there is the pos­si­bil­i­ty that despite Sirqul’s rea­son­able efforts, there could be unau­tho­rized access to your per­son­al data. By using the Ser­vices, you assume this risk.

10. Oth­er

Please be aware of the open nature of cer­tain social net­work­ing and oth­er open fea­tures of the Ser­vices Sirqul 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. Sirqul is not respon­si­ble for any per­son­al data you choose to make pub­lic in any of the­se forums.

If you are under 13 years of age or a minor in your coun­try of res­i­dence, please ask your legal guardian’s per­mis­sion to use or access the Ser­vices. Sirqul encour­ages par­ents and/or guardians to play an active role in their children’s online expe­ri­ence at all times. Sirqul does not know­ing­ly col­lect any per­son­al infor­ma­tion from chil­dren under 13 years of age and if Sirqul learns that Sirqul has inad­ver­tent­ly gath­ered per­son­al data from chil­dren under 13 years of age, Sirqul will take rea­son­able mea­sures to prompt­ly erase such per­son­al data from Sirqul ‘s records.

Sirqul 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. Sirqul may dis­close your per­son­al data to third par­ties in con­nec­tion with a cor­po­rate merg­er, con­sol­i­da­tion, restruc­tur­ing, the sale of sub­stan­tial­ly all of Sirqul’s stock and/or assets or oth­er cor­po­rate change, includ­ing, with­out lim­i­ta­tion, dur­ing the course of any due dili­gence process pro­vid­ed, how­ev­er, that this Pri­va­cy Pol­i­cy shall con­tin­ue to gov­ern such per­son­al data.

11. Fur­ther infor­ma­tion

Pur­suant to Sec­tion 10, Finnish Per­son­al Data Act (523/1999), the data con­troller is Sirqul, Inc., address 81 Vine Street, Suite 101, Seat­tle, WA 98121. The name of the per­son­al data file is “Sirqul Ser­vices’ Data File”. Any and all use of your per­son­al data by Sirqul is gov­erned by Unit­ed States law and not the laws where you may be locat­ed.

Should you wish opt-out from receiv­ing com­mu­ni­ca­tions (such as newslet­ters or offers) from Sirqul, please con­tact unsubscribe@sirqul.com.

Sirqul makes good faith efforts to enable you to review, update or cor­rect your per­son­al data in Sirqul’s pos­ses­sion. In order to do so, please con­tact Sirqul at privacy@Sirqul.com. Sirqul 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. Please note that even if per­son­al data is changed or delet­ed accord­ing to your request, Sirqul may still retain some of your per­son­al data to resolve dis­putes, enforce Sirqul user agreement(s), and com­ply with tech­ni­cal and legal require­ments and con­straints relat­ed to the secu­ri­ty, integri­ty and oper­a­tion of Sirqul Ser­vices.

Sirqul reg­u­lar­ly reviews its com­pli­ance with this Pri­va­cy Pol­i­cy. If Sirqul receives a for­mal writ­ten com­plaint from you, Sirqul will attempt to con­tact you direct­ly to address any of your con­cerns. Sirqul 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 Sirqul. Any dis­pute, con­tro­ver­sy or claim aris­ing out of or relat­ing to this Pri­va­cy Pol­i­cy or the breach, ter­mi­na­tion or valid­i­ty there­of shall be final­ly set­tled at Sirqul ‘s dis­cre­tion (i) at your domicile’s com­pe­tent courts; or (ii) by arbi­tra­tion. The arbi­tra­tion shall be con­duct­ed in Seat­tle, Wash­ing­ton, USA, in the Eng­lish lan­guage. YOU AGREE THAT YOU MAY BRING CLAIMS AGAINST SIRQUL ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.