Flare Star LLC
Privacy Policy
Last
Updated: October
28, 2022
Flare Star LLC develops and publishes social
games for the web and mobile devices. This Privacy Policy (this “Policy”)
describes the ways Flare Star LLC (“Studio,” “us”, “our” or “we”) collects,
stores, uses, discloses or otherwise processes personal information of our
users (“users” or “you”) in connection with their use of our products or
services, including our product offerings such as our website available at https://www.flarestar.fun and Studio game(s) provided on a mobile platform or any
other Studio product or service that posts or links to this Policy (each a
“Service,” collectively, the “Services”). Additionally, this Policy
describes the rights and choices concerning your information that may apply to
you.
●
Personal information we collect and
how we collect it
●
Security of
your information
●
Third-party
websites and services
●
Transfer of
personal information outside your country
●
Specific
provisions for EEA, UK and Swiss individuals
●
Specific
provisions for California Consumers
If you have questions regarding this Policy or
our collection and use of personal information, please contact us as described
in the Section “Contact Us”.
1. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
When you interact with or use our Services, we
are collecting personal information about you. Sometimes we collect personal
information automatically when you interact with our Services (e.g., information
about how you interact with our Services) and sometimes we collect the personal
information directly from you when you use our Services (e.g., information you
give us when setting up your account or user profile). At times, we may collect personal information
about you from other sources and third parties, including other players.
Registration
Information
We may offer you the option to complete a user
profile that is visible to other Studio users (“Account”). If you create an
Account, you may provide us your name, a username, e-mail address, a password
and other information that helps us confirm that it is you accessing your
Account. We may do this through
in-game dialog boxes, which you may choose to skip. If you sign into the
Services with Facebook Connect, we will 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. Your Account may be
used to publicly identify you as part of social features of the Services, which
may include user-to-user interaction, chat or messaging functionality, public
leaderboards, head-to-head competition, and other similar features. Your
username associated with your Account will be public and will be shown to other
users. In addition, your username will allow
others to access information on your user profile that is considered public or
that you have designated as public in your user profile settings.
Address
Book Information
We may also offer you the ability to choose to
import your contacts or manually enter e-mail addresses so that you can locate
your contacts on Studio and invite your contacts to join you in the Services.
This information is typically collected through the use of third-party mobile
device software development kits. If you choose to import your contacts or
manually enter e-mail addresses, we will store those contacts for purposes of
helping you and your contacts make connections through our Services. You are
responsible for ensuring your sharing of this information with us is compliant
with applicable laws. In some countries, this may require you to get permission
from the people you invite before you share their information.
Technical
and Usage Information
When you
access our Services, we may use cookies and other similar technologies to
collect (i) certain technical information about your mobile
device or computer system, including IP Address, mobile device ID (IDFA, Google
Advertising ID or other identifiers), and the version of your operating system;
and (ii) usage statistics about your interactions with the Services, including
the links, objects, products and benefits you view, click or otherwise interact
with (also known as “Clickstream Data”). Our emails may also contain tracking
pixels that identify if and when you have opened an email that we have sent
you, how many times you have read it and whether you have clicked on any links
in that email. In connection with your use of certain Services, we will create
and assign to your device an identifier that is similar to an account number. In
addition, in certain circumstances, we may collect the name you have associated
with your device, device type, telephone number, country, and any other
information you choose to provide, such as username, character name, or e-mail
address. We may also infer your approximate geographic
location based on your IP address.
Payment
Information
When you
order any good or service through the Services, including any virtual currency
or virtual good, we collect certain non-financial transaction information
related to these purchases, including what you purchased, the price, and the
date. Your
in-app purchase transactions are processed by third-party payment processors,
such as Apple (for purchases on iOS devices), Google (for purchases on Android
devices), or Amazon (for purchases on Kindle devices). The third-party payment
processors will collect your name, phone number, e-mail address, mailing
address, billing address, and complete credit card information to enable them
to process your payment. The third-party payment processors may also retain
this information to enable you to purchase additional items through our
Services without having to re-enter your payment information each time. Please note third-party payment processors do
not share your financial information, like credit card numbers, with us. In
addition, please note that the third-party payment processors’ processing of
transactions and collection and use of your personal information is governed by
their terms of service and privacy policy, and purchases through these third parties may also be subject
to additional policies. We
encourage you to review the terms of service and privacy policies of those third
parties to learn more about how they handle your personal information.
Information
Collected by or Provided to Customer Support
When you
ask for assistance from our Customer Support team, we will collect and store
the contact information you provide (generally your name and e-mail address),
information about your game-play or activity on the Services, and your username
or ID number. We will also store the correspondence and information within the
correspondence that you choose to share with us.
Communication Preferences
We may
collect information about your interests and communication preferences that you
choose to provide, such as when subscribing to news or alerts.
Surveys, User Research Projects, Competitions
and Promotional Events
If you choose
to participate in, or fill out any forms relating to, Studio surveys, user
research projects, competitions (contests/sweepstakes), promotional events, or
similar activities, we will collect your contact information (such as your
name, email, and phone number, address and postal code) to enable you to
participate in the activity and to allow us to communicate with you, as well as
any other information that we request that you provide for purposes of the
activities, including audio or video recordings, photos, and/or screen
captures. In connection with Studio
surveys and user research projects, we may also collect your age, gender,
opinions, responses to certain research questions, prompts, or surveys, and
other personal information, consistent with the purposes of the Studio survey
or user research project.
On
occasion, we may also collect your shipping and billing information to send you
certain rewards or incentives, such as if you are a participant in a Studio survey or user research project, a competition winner,
or if you purchase our products or services.
In addition, if you are a part of our event or promotion partner, we may
also collect your personal information including your name, company email, and
company address.
Please note
that your participation in any Studio surveys, user research projects,
competitions (contests/sweepstakes), promotional events, or similar activities,
is completely voluntary.
We may collect or receive information from the
following other sources (i) other Service users who
choose to upload their email contacts; (ii) third party information providers,
such as digital advertising companies; and (iii) social networking sites. We
may combine this information with the information we collect from an individual
directly.
C. Sensitive or
Special Categories of Information
We typically do not
request or seek to elicit sensitive or special categories of information, but
you may choose to provide this information to us in connection with certain of
the interactions described above, including when you ask for assistance from
our Customer Support team. The meaning of sensitive or special categories of
information varies by jurisdiction and it could include, for example, health,
genetic or biometric data, or precise location information.
2. HOW WE USE YOUR
INFORMATION
We use information collected through our Service
for purposes described in this Policy or disclosed to you in connection with
our Service. For example, we may use your information for:
Service Delivery
−
Create your
Service accounts and allow access to our Services;
−
Identify
and suggest connections with other Studio users;
−
Operate our
Services;
−
Improve our
Services;
−
Understand
you and your preferences to enhance your experience and enjoyment using our
Services;
−
Respond to
your comments and questions and provide customer service;
−
Provide and
deliver products and services you request;
−
Send you
related information, including confirmations, invoices, technical notices,
updates, security alerts, and support and administrative messages;
−
Conduct and
administer surveys, user research projects, competitions and promotional events
that you participate in;
−
Prevent
fraud or potentially illegal activities, and enforce our Terms of Use;
−
Enable you
to communicate with other users; and
−
Fulfill any
other purpose for which you provide personal information.
Marketing and Advertising
−
Deliver and
target advertising and marketing and promotional information to you; and
−
Communicate
with you (including via email and push notifications) about promotions,
contests, rewards, upcoming events, and other news about products and services
offered by us and our selected partners.
Research and Development
−
Create
aggregate or anonymous information derived from the personal information we
handle, which we may use and disclose for research, development and other
lawful business purposes;
−
Link or
combine personal information with other information we get from third parties
to help understand your preferences and provide you better services; and
−
Analyze
information to choose to provide to us in connection with Studio surveys and user
research projects to gain insights into how users engage with our Services, to
improve our Services, to consider developing new products or services, and other
lawful purposes.
−
Comply with
applicable laws, lawful requests, and legal process, such as to respond to
subpoenas or requests from government authorities;
−
Protect
our, your or others’ rights, privacy, safety or property (including by investigating,
bringing, making or defending legal claims);
−
Audit our
internal processes for compliance with legal and contractual requirements or
our internal policies;
−
Enforce the
terms and conditions that govern the Services; and
−
Prevent,
identify, investigate and deter fraudulent, harmful, unauthorized, unethical or
illegal activity, including cyberattacks and identity theft.
Push Notifications
We may occasionally send you push notifications
through our Service to send you game updates, high scores and other
service-related notifications that may be of importance to you. You may
at any time opt-out from receiving these types of communications by turning
them off at the device level through your settings.
3. SHARING OF YOUR INFORMATION
We may share information we collect for the
following purposes:
−
Service
Providers. With service providers that perform services
on our behalf or enhance our Services, including hosting services, customer
service, analytics services and to assist us in our marketing efforts;
−
Payment
Processors. With third-party
payment processors that process payments you make;
−
Advertising
Partners. Advertisers, ad
exchanges and other ad technology companies that require the data to select and
serve our relevant advertisements to you and others, and assist us in our
marketing efforts, including as described in the Online Advertising section
below;
−
Affiliates. With our
parent company, subsidiaries and other affiliates;
−
Professional
Advisors. With professional
advisors, such as lawyers, auditors, bankers and insurers, where necessary in
the course of the professional services that they render to us;
−
Authorities
and others. With law
enforcement and public authorities, as we believe in good faith to be necessary
or appropriate for the compliance and protection purposes described above;
−
Business
Transferees. With acquirers and
other relevant participants (and their advisors) in business transactions (or
negotiations of or due diligence for such transactions) involving a corporate
divestiture, merger, consolidation, acquisition, reorganization, sale or other
disposition of all or any portion of the business or assets of, or equity
interests in, Studio or our affiliates (including, in connection with a
bankruptcy or similar proceedings); and
−
Your
specified recipients. We may
disclose personal information about an individual to certain other third
parties or publicly with their consent or direction.
Interest-Based
Advertising
To the extent we display advertising in our
Services, with your consent as may be required by applicable law, we may share
or we may allow online advertising networks, social media companies, and other
third-party services to collect information about your use of our Services over
time to enable them to play or display ads on our Services, on other devices
you may use, and on other websites, apps, or services. Typically, though not always, the information
we share is provided through cookies, software integrations, or similar
tracking technologies, which recognize the device you are using. We and our third-party partners use this
information to try to make the advertisements you see online more relevant and
tailored to your interests, as well as to provide advertising-related services
such as reporting, attribution, analytics, and market research. Such information includes the following:
- Device make, model and operating system;
-
Device
properties related to screen size & orientation, audio volume and battery;
-
Carrier;
-
Operating
system;
-
Name and
properties of mobile application through which the user interacts with the
Services;
-
Country,
time zone and locale settings (country and preferred language);
-
Network
connection type and speed;
-
IP Address;
-
Gender;
-
Keywords;
-
City-and/or
country-level geolocation data;
-
Internet
browser user-agent used to access the Services; and
-
Advertising
ID (IDFA on iOS devices and GAID on Android devices).
A list of these advertising partners and their
privacy policies is available at https:// flarestar.fun/advertising-partners.pdf. The
privacy policies of our partners may include additional terms and disclosures
regarding their data collection and use practices. We encourage you to review
those privacy policies to learn more about their data collection and use
practices.
Our Service may include social media features,
such as the Facebook button, Google, Instagram, Twitter, or other widgets. These social media companies may recognize
you and collect information about your visit to our Services, and they may set
a cookie or employ other tracking technologies.
These companies have interest-based advertising programs that allow us
to direct advertisements to users who have shown interest in our Services while
those users are on the social media platform or to groups of other users who
share similar traits, such as likely commercial interests and
demographics. Your interactions with
those features are governed by the privacy policies of those companies.
We, or our third-party partners, may link your
various devices so that content you see on one device can result in relevant
advertising on another device. We do
this by collecting information about each device you use when you are logged in
to our Service. We may also work with
third-parties who employ tracking technologies or the application of
statistical modeling tools to determine if two or more devices are linked to a
single user or household. We may share a
common account identifier (such as an email address or user ID) with
third-party advertising partners to help recognize you across devices. We, and our partners, can use this
cross-device linkage to serve interest-based advertising and other personalized
content to you across your devices, to perform analytics, and to measure the
performance of our advertising campaigns.
We utilize certain forms of display advertising
and other advanced features through Google Analytics, including, but not
limited to, Remarketing with Google Analytics, the DoubleClick Campaign Manager
Integration, Google Ads, and Google Analytics Demographics and Interest
Reporting. These features enable us to use first-party cookies (such as the
Google Analytics cookie) and third-party cookies (such as the DoubleClick
advertising cookie) or other third-party cookies together to inform, optimize,
and display ads based on your past visits to the Service and to tailor our
advertisements and content to you. You
may control your advertising preferences or opt-out of certain Google
advertising products by visiting the Google Ads Preferences Manager, currently
available at https://google.com/ads/preferences. To learn how you can opt-out of data collection by Google
Analytics, visit https://tools.google.com/dlpage/gaoptout.
Opting-Out
of Interest-Based Advertising
You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about
interest-based advertising and how to opt-out of this form of advertising on
your web browser by companies participating in the Digital Advertising Alliance
(“DAA”) self-regulatory program. If you
wish to opt-out of interest-based advertising in mobile apps on your device by
companies that participate in the DAA’s AppChoices
app, you may download that app onto your device and exercise your choice. AppChoices is
available at the links below:
You may also limit data collection by third
parties by visiting your mobile device settings and adjusting the device’s ad
tracking settings (such as turning off the feature to “Allow Apps to Request to
Track”) or by exercising other privacy options in your device’s settings.
Please note that electing to opt-out will not
stop advertising from appearing in your browser or applications or reduce the
number of ads that you receive. You will
still receive ads, but those ads may be less relevant to your interests. In addition, if you use a different browser
or erase cookies from your browser, or use a different mobile device, you may
need to apply your opt-out choices to that particular
browser or device.
Please note that the opt-out tools described in
this section are provided by third parties, not by us. We do not control and are not responsible for
the effectiveness of, or compliance with, any third-parties’ opt-out options or
programs or the accuracy of their statements regarding their programs. In
addition, third parties may still use cookies to collect information about your
use of our online services, including for analytics and fraud prevention as
well as any other purpose permitted under the DAA’s Principles.
Do Not Track
Some Internet browsers may be configured to send
“Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track”
or similar signals. To find out more
about “Do Not Track,” please visit http://www.allaboutdnt.com.
5.
SECURITY OF YOUR
INFORMATION
We implement reasonable and appropriate technical
and organizational measures to protect the security of your personal
information against accidental or unlawful destruction, loss, change or damage.
However, no security system is impenetrable, and
we cannot guarantee the security of your personal information. Any transmission is at your own risk.
We store data on servers in the U.S. or any
other country in which the Studio or its affiliates, subsidiaries, agents or
contractors or service providers maintain facilities. We retain your personal information
for as long as needed to provide you Services, unless we are required by law to
delete or if we accept your request to delete the information pursuant to
applicable law. We will also retain and use your personal information as
necessary to comply with our legal obligations, resolve disputes, and enforce
our agreements.
When we no longer
require your personal information, we will look to delete or anonymize it or, if
this is not possible (for example, because your personal information has been
stored in backup archives), then we will apply security measures to your
personal information and isolate it from any further processing until deletion
is possible. If we anonymize your personal information (so that it can no
longer be associated with you), we may use this information indefinitely
without further notice to you.
7. CHILDREN’S PRIVACY
The Services are not intended for use by
children (aged 16 or such higher age as required by applicable law). We do not
knowingly collect personal information from children through the Services or
knowingly allow them to use our Services. If we learn that we have unintentionally
collected personal information from a child, we will delete that
information. If you believe that we might have collected personal information
from or about a child, please contact us at privacy@flarestar.fun.
8.
THIRD-PARTY WEBSITES AND SERVICES
The Services may contain integrations or links
to third-party websites or services, including those of our business
partners. By interacting with these
third parties, you are providing information directly to the third party. Please note that the Studio is not
responsible for the privacy practices of these third parties or any entity that
it does not own or control. We encourage
you to review the privacy policies and online terms of those third parties to
learn more about how they handle your personal information.
9.
TRANSFER OF PERSONAL INFORMATION OUTSIDE
YOUR COUNTRY
We may transfer information that we collect
about you to affiliated entities, or to other third parties across borders and
from your country or jurisdiction to other countries or jurisdictions around
the world. If you are located in the European Economic Area, United Kingdom or
Switzerland, your personal information may be processed outside of those
regions, including in the United States.
Subject to certain exemptions, you can manage information
we receive about you.
If you would like us to delete your information, you may
send an e-mail to privacy@flarestar.fun and place “Delete My
Account” in the subject line or request to delete your information inside the
app you are using. If you proceed
with the deletion of your account, you will no longer have access to the game
account or services associated with your account. Other steps you should
take should you wish to delete your account include disassociating your
Facebook account from our mobile games, if applicable, and deleting the game
from your mobile device. Please note that if you ask us to delete your
account, all your progress in the game and any unused virtual items will be
lost and we may not be able to restore them in the future. Please note
that your information, for example records pertaining to payments or customer
service matters, may be retained for legal and accounting purposes. If you have
sent or posted content on the Service, we may not be able to delete it.
If
you wish to review, change or correct the information we have about you, you may send an e-mail to privacy@flarestar.fun making this request.
For all of the above
requests, we will need to verify your identity before processing your request.
In order to verify your identity, we will generally require the matching of
sufficient information you provide us to the information we maintain about you
in our systems.
11. SPECIFIC PROVISIONS FOR EEA, UK AND SWISS INDIVIDUALS
These additional provisions apply to individuals
who are located in European Economic Area (“EEA”), United Kingdom (“UK”) and
Switzerland.
Flare Star LLC, having its registered address at 2100 Geng Road,
Suite 210 Palo Alto, CA 94303, is
the “data controller” responsible for the processing of personal data in
connection with our Services. This means that we determine and are responsible
for how your personal information is used.
Your
Rights With Respect to Your Personal Information
In accordance with applicable privacy law, you
have the following rights in respect of your personal information that we hold:
-
Accessing and Correcting Your Personal
Information. At any time, you may request to access the personal
data that we hold about you. We may need to ask you to provide certain
information to make sure you are who you claim to be. If you find the
information on your account is not accurate, complete or updated, then please
provide us with the necessary information to correct it.
- Erasing
or Restricting Access to Your Information. You may request to
delete or restrict access to your personal data. We may postpone or deny your
request if your personal data is in current use for providing Services or for
other legitimate purposes, in which case we will let you know if we are unable
to do so and why.
- Transferring
Your Personal Data (Otherwise Known as Your Right to Data Portability). You
have the right to receive your personal data that you have provided us in a
structured, commonly used and machine readable format
and the right to transmit that data to another party of your choice, where
technically feasible. However, this right shall not apply where it would
adversely affect the rights and freedoms of others.
- Right
to Object to Processing. You have the right to object to our processing
of your personal data, under certain conditions.
- Withdrawing
Your Consent. Contact us if you
would like to withdraw your consent to the processing of your personal data
based on that consent. Exercising this right will not affect the lawfulness of
processing based on consent before withdrawal.
If you wish to exercise any of your rights
detailed above, please contact us at privacy@flarestar.fun or write to us at the
address set forth in the “Contact Us” section. If you make a request, we will typically
look to respond within one month, although a longer period may be permitted.
Right
to Make a Complaint. In the event that you wish to make a complaint
about how we process your personal data, please contact us in the first
instance at
Lawful
Basis for Processing
With respect to each
of the purposes for which we use your personal information (see Sections 2, 3
and 4 above), the lawful basis that we may rely upon will vary based on the
nature of, and reason for, particular use to which we are putting your personal
information. However, typically we will use your personal information:
● Where we need to do so to
perform a contract we are about to enter into with you
or have entered into with you – for example, this will be relevant where we use
your personal information to provide you with the Services, to operate the
Services and to create and maintain
your Account.
● Where it is necessary for our
legitimate interests, and/or those of a third party, and your interests and
fundamental rights do not override those interests – for example, this will be
relevant where we share your personal information in the context of an actual or prospective corporate event, in
these cases we and
any relevant third parties have a
legitimate interest in enabling those parties to investigate and, where
relevant, to continue to operate, all or relevant part(s) of our
operations.
● Where we need to comply with a
legal or regulatory obligation – for example, this will be relevant where we
are legally obliged to provide your personal information to authorities to
comply with lawful governmental or regulatory requests.
● Where we have your specific
consent to carry out the processing for the purpose in question – for example,
this will be relevant where we use your personal information to show you targeted
online advertising.
For questions about the lawful basis we rely on for data processing, please contact us at privacy@flarestar.fun. Visit the “Contact Us” section below for contact information.
Marketing
and Advertising
From time to time we may contact you with
information about our services, including sending you marketing messages and
asking for your feedback on our services. Most marketing messages we send will
be by email or push notifications. For some marketing messages, we may use
personal information we collect about you to help us determine the most
relevant marketing information to share with you.
Where we rely on consent to send you marketing
communications, we will only send you such messages if you have given us your
consent to do so. You can withdraw your consent at a later date by clicking on
the “unsubscribe” link at the bottom of our marketing emails or by updating
your preferences in the settings page of the App or Service.
Data Transfers
and Processing Outside Europe
If you are located in the
EEA, UK or Switzerland, your personal information may be processed outside of
those regions, including in the United States. In the event of such a transfer,
we typically try to ensure a degree of protection similar to that applied in
your home country is afforded to it by employing one of the following
mechanisms:
In limited circumstances, we may
rely on an exception, or ‘derogation’, which permits us to transfer your
personal information to recipients in such countries despite the absence of an
‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your
explicit consent to that transfer.
If you want further
information on the specific mechanism(s) used by us when transferring your
personal information, please contact us at privacy@flarestar.fun. Visit the “Contact
Us” section below for contact information.
12. SPECIFIC PROVISIONS FOR CALIFORNIA CONSUMERS
These additional
provisions for California consumers apply only to individuals who reside in
California. The California Consumer
Privacy Act of 2018 (“CCPA”) and California
Privacy Rights
Act of 2020(“CPRA”) provide additional rights to know, access, correct, delete, and opt out, and requires “businesses”
collecting or disclosing personal information to provide notice and a means to
exercise those rights.
Your California Privacy Rights. California
residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline
your request as permitted by law.
Right to Opt Out of Information Sales
We do not “sell” information about our users as most
people would commonly understand that term.
However, consistent with common practice among companies that operate
online, we do “share” information in the sense that we allow certain
third-party advertising networks and other third-party businesses to collect
and disclose your personal information directly from your browser or device
through cookies or tracking technologies when you visit or interact with our
websites, use our apps or otherwise engage with us. These third parties use
your personal information for purposes of analyzing and optimizing our Service
and advertisements on our websites, on other websites or mobile apps, or on
other devices you may use, to personalize content or to serve ads that may be
more relevant to your interests, and to perform other advertising-related
services such as reporting, attribution, analytics and market research. To
learn more about how third parties collect information automatically on our
Site and the choices you may have in relation to those activities, please see
our Online Advertising section, above.
How to
Exercise Your Rights
To exercise your right to know, right to access,
right to correct, right to delete, right to opt out of information sales, or
any other right you may have under applicable law, please submit a request by
emailing privacy@flarestar.fun or by writing to us at the physical address in the
“Contacts” section below, with the subject line “California Rights Request” and
specifying which right(s) you would like to exercise (for example, your right
to delete). We will need to verify your
identity before processing your request. In order to verify your identity, we
will generally require the matching of sufficient information you provide us to
the information we maintain about you in our systems. In certain circumstances,
we may decline a request to exercise the rights described above, particularly
where we are unable to verify your identity or
locate your information in our systems. If we are unable to comply with all or
a portion of your request, we will explain the reasons for declining to comply
with the request.
In certain circumstances, you are permitted to
use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the
requestor is an authorized agent with written permission to act on your behalf
and (ii) you successfully verify your own identity with us.
We aim to respond to a consumer request within
45 days of receiving that request. If we require more time, we will inform you
of the reason and extension period in writing.
Personal Information That We Collect, Use and Disclose. The chart below summarizes the Personal
Information we collect by reference to the categories of Personal Information
specified in the CCPA, and describes our practices currently and during the 12
months preceding the effective date of this Privacy Policy. See Sections 1-3 of
our Privacy Policy for additional details. Information you voluntarily provide
to us, such as in free-form webforms, may contain other categories of personal
information not described below. We do not intentionally collect or seek to
elicit “sensitive personal information” under the CPRA.
Category of Personal Information Collected |
Source(s) of Personal Information |
Business Purpose(s) for Collection |
Categories of Third Parties to Whom We Disclose the PI
for a Business Purpose |
Identifiers, such as name, user
name, email address and other contact information, IP address, and online
identifiers (like advertising IDs and cookies) |
·
You or your device(s) ·
Advertising partners ·
Affiliates |
·
Service delivery ·
Delivery of advertisements ·
Technical support ·
Customer support ·
Processing payments ·
Analytics ·
Business research & development ·
Marketing & promotions ·
Platform protection & fraud prevention ·
Compliance with legal obligations |
·
Service providers ·
Affiliates ·
Your specified recipient(s) ·
Government entities/law enforcement ·
Advertising partners shared* for interest based advertising |
Additional
California Customer Records, such as address book information |
·
You or your device(s) |
·
Service delivery ·
Analytics ·
Business research & development ·
Marketing & advertising |
·
Affiliates ·
Your specified recipients |
Characteristics of
Protected Classifications, such as age or gender |
·
You or your device(s) |
·
Service Delivery ·
Delivery of advertisements ·
Analytics ·
Business research & development ·
Platform protection & fraud prevention ·
Compliance with legal obligations |
·
Service providers ·
Affiliates ·
Your specified recipient(s) ·
Government entities/law enforcement ·
Advertising partners shared* for interest based advertising |
Commercial
Information, such as purchase history, in-app purchases, or other
purchasing or consuming histories or tendencies |
·
You or your device(s) |
·
Service Delivery ·
Delivery of advertisements ·
Analytics ·
Business research & development ·
Platform protection & fraud prevention ·
Compliance with legal obligations |
·
Service
providers ·
Affiliates ·
Your
specified recipients ·
Payment
processors ·
Advertising
partners shared* for interest based advertising |
Internet or Network Information, such as
information regarding interactions with a website, application, or
advertisement |
·
You or your device(s) |
· Service delivery · Delivery of advertisements · Analytics · Business research & development · Platform protection & fraud prevention ·
Compliance with
legal obligations |
· Service providers · Affiliates · Your specified recipients · Government entities/law enforcement · Advertising
partners shared* for interest based advertising |
Geolocation Data, such as
city or county-level geolocation information |
·
You or your device(s) |
· Service delivery · Delivery of advertisements · Analytics · Business research & development · Platform protection & fraud prevention ·
Compliance with
legal obligations |
· Service providers · Affiliates · Your specified recipients · Government entities/law enforcement ·
Advertising partners shared* for interest based advertising |
Inferences, such as the derivation of
information, data, or assumptions from the categories of personal information
included above |
·
You or your device(s) |
· Service delivery · Delivery of advertisements · Analytics · Business research & development · Platform protection & fraud prevention ·
Compliance with
legal obligations |
· Service providers · Affiliates · Advertising
partners shared* for interest based advertising |
*Pursuant to the CPRA and as further described above this information is “shared” with
advertising partners for interest-based advertising.
We may update this Policy to reflect changes to
our data and information privacy practices. If we make any material changes, we
will notify you by means of a notice on the Services prior to the change
becoming effective. We encourage you to periodically review this Policy for the
latest information on our privacy practices. Please note that if we need
to adapt the Policy to legal requirements, the new Privacy Policy will become
effective immediately or as required.
13. CONTACT US
Our
Data Protection Officer
You may contact us at privacy@flarestar.fun
2100 Geng
Road, Suite 210 Palo Alto, CA 94303.