Ludia – JWA EU Privacy Notice – Jurassic World Alive

Effective Date: April 23^rd, 2019

Prior Privacy Policy dated November 20^th, 2018 is available here.

Introduction:

Jurassic World Alive and its online forum (www.forum.ludia.com/c/JurassicWorldAlive) and FAQ (www.ludia.helpshift.com/a/jurassic-world-alive/) ( collectively, the “App”), which are owned and operated by Ludia, Inc. (collectively “Ludia“, “we”, “us”, “our”), which is committed to fulfilling our responsibilities under the European Union’s General Data Protection Regulation (“GDPR”) in relation to the collection, retention, use, and other processing of personal data that is obtained when EU data subjects download, use, and interact with the App. This Privacy Notice sets forth how we process EU personal data in our role as a data controller (i.e., when we are responsible for determining the purpose and means of the processing).

Personal Data We Collect

We may collect and process the following information when you interact with the App.

Contact data.You may provide us with your contact details, such as name, email address, or other similar information.
Account Information. In addition to contact data, when creating an account you may provide us with additional information about yourself including personal data associated with social media accounts you link to your App account (e.g., Facebook).
Authentication Data. To verify the identity of registered users we may collect authentication information.
Device Information. We may obtain information about devices that access our App, including the type of device, its operating system, device settings, unique device identifiers, and error data.
Location Information. We may collect and use general location information (e.g., zip code) or specific location information (e.g., real-time GPS coordinates) from devices used to access the App.
User-Generated Content. You may provide us information contained in user-generated content you submit to the App such as comments and posts on the App’s forum. Please be aware that information you post on public parts of the App may be visible to anyone.
Other Information You Provide. This includes emails and other communications that you send us or otherwise contribute, such as customer support inquiries regarding the App.

Some features of the App may open your preferred internet browser on your device and allow you to access certain websites. These websites are governed by their own privacy policies, terms, and cookie policies. Understand that this Notice does not apply to any website or any other mobile application. We encourage you to read the policies and terms of websites and mobile applications that the App may link to.

How and Why We Use Your Personal Data

We may process personal data to:

Transact with you, respond to your comments, questions and requests, provide customer service, send you informational notices, and contact you if we need to obtain or provide additional information;
Facilitate, manage, personalize, and improve our customer and partner relationships;
Prevent and address fraud, breach of policies or terms, and threats or harm;
Ensure the security and integrity of the personal data we process; or
Comply with applicable legal requirements.

Our processing of such personal data is carried out pursuant to the following legal bases:

The processing is necessary for us to provide you with the services and products you request, or to respond to your inquiries.
We have a legal obligation to process your personal data, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
To protect your vital interests, or those of others.
We have a legitimate interest in carrying out the processing activity. In particular, we have a legitimate interest in the following cases:
- To analyze and improve the safety and security of the App. This includes implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
- To maintain and improve the App.
- To operate the App and provide you with certain tailored advertising and communications to develop and promote our business.
You have consented to the use of your personal data. When you consent, you can change your mind at any time.

If we make a material change to how we process your personal data, we will notify you as appropriate and may also modify this Privacy Notice.

How We May Share Your Personal Data

We may share your personal data:

With our affiliates or business partners when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the App.
With our agents, vendors, consultants, marketing service providers, and other service providers who perform functions on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other platforms, and send marketing and other communications on our behalf.
To abide by applicable law or protect rights and interests. For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or prevent fraud or abuse.
If we are involved in a reorganization, merger, acquisition, sale, or other business transaction involving some or all of our assets.

How We Use Tracking Technologies

We utilize online identification tools—such as cookies, web beacons, pixels or similar tracking technologies—in accordance with applicable law and requirements. “Cookies” are small text files placed on your device when you visit a website; they store information which is sent back to our servers or those of third parties. As described in more detail below, we use such technologies to:

Recognize new or past users;
Store your profile or authentication credentials if you are registered on the App;
Improve the App and to better understand your use of the App;
Integrate with third-party social media websites;
Serve you with interest-based or targeted advertising;
Observe your behaviors and browsing activities over time across multiple websites or other platforms; and to
Better understand the interests of our App users.

Some cookies are required for certain uses of the App. For example, if you choose to register an account through the App, we will use cookies to facilitate your registration and remember your preferences.

Different types of cookies may be used for specific purposes, for example:

Functional cookies and cookies from third parties may be used for analysis and marketing purposes. Functional cookies enable certain parts of the website to work properly, retain user preferences, and allow users to log in using social network user credentials.
Analysis cookies may collect information on how visitors use a website, the content and products that website users view most frequently, and the effectiveness of third-party advertising.
Advertising cookies assist in delivering ads to relevant audiences. This may include, for example, placing ads at the top of search results.

Cookies are either “session” cookies which are deleted when you end your browser session, or “persistent,” which remain until you delete them or the party who served the cookie removes it. Further details concerning the cookies we use on our App are available in the table included at the bottom of this section.

Through your device settings, you may change your App settings to disallow certain App features and certain tracking technologies. For example, turning off location tracking through your device’s settings will disable the App’s location tracking technologies. You can set your browser settings either to receive our cookies or use our App without cookie functionality. To control flash cookies visit this link. Please note that if you restrict the use of tracking technologies, some functions of the App may be unavailable and we will not be able to present you with personally-tailored content.

We may link the information collected by tracking technologies with other information we collect from you pursuant to this Privacy Notice. Similarly, the third parties who serve tracking technologies on our App may link personal data we collect from you to other information they collect.

Provider	Purpose	Persistent / Session	Duration
Unity 3D	Track device specifications	Persistent	1 month
Amplitude	Track player’s actions in game for accounting, security and game optimisation	Persistent	10 years or when the game is decommissioned (whatever comes first)
Adjust	Track user acquisition	Persistent	10 years or when the game is decommissioned (whatever comes first)
Helpshift	Submit support request in-game and via website	Persistent	10 years or when the game is decommissioned (whatever comes first)
Discourse	Authenticate player in the forum (cookie)	Session and Persistent	Up to 2 years

How We Protect Your Personal Data

We maintain appropriate technical and organizational safeguards designed to help protect personal data from unauthorized disclosure or access and accidental or unlawful destruction, loss, or alteration. Although we use reasonable efforts to safeguard personal data, we cannot guarantee the security of your information obtained through the App

How Long We Retain Your Personal Data

We will store your personal data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal data from our systems and records or take appropriate steps to properly anonymize it.

Personal Data Transfers

As required by law, we will obtain appropriate consent from EU data subjects prior to transferring their personal data out of the EU to a country that has not been deemed by the European Commission to provide an adequate level of personal data protection. Please contact us if you have questions regarding our cross-border data transfer activities.

Your Rights and Choices

The GDPR provides EU data subjects with certain rights regarding their personal data. Subject to certain conditions, you may ask Ludia to take the following actions in relation to your personal data that we hold:

Provide you with information about our processing of your personal data and give you access to your personal data.
Update or correct inaccuracies in your personal data.
Delete your personal data.
Transfer a machine-readable copy of your personal data to you or a third party of your choice.
Restrict the processing of your personal data.
Object to our processing of your personal data for direct marketing purposes.
Object to reliance on our legitimate interests as the basis for processing of your personal data.

You can submit these requests by email to GDPR@ludia.com or our postal address provided below. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal data or our response to your requests regarding your personal data, you may contact us at GDPR@ludia.com or submit a complaint to the data protection regulator in your jurisdiction. You can find information about your data protection regulator here.

How to Contact Us

In order to make a query, raise a concern, or exercise your data protection rights, please contact us at GDPR@ludia.com

The data controller for your personal data is Ludia, Inc., which you may contact by via email at GDPR@ludia.com, by phone at 011-1-514-313-3370 ext 201, or at the following address:

Ludia, Inc.
RE: GDPR Privacy
410 St-Nicolas Street, Suite 400
Montreal, Quebec H2Y 2P5
Canada

You may contact our Data Protection Officer via email at DPO@ludia.com, by phone at 011-1-514-313-3370 ext 201, or at the following address:

Ludia, Inc.
ATTN: EU Data Protection Officer
410 St-Nicolas Street, Suite 400
Montreal, Quebec H2Y 2P5
Canada