Last updated: 8 Feb 2013
1. Non-personal data
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 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
4. Personal Data
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.
5. Disclosure and Transfer of Personal Data
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
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.
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.
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 firstname.lastname@example.org.
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.