CHIEF PUZZLE OFFICER PRIVACY STATEMENT

Last Modified on January 12, 2016

Our Privacy Commitment

DuoFun Studios, Inc. (“DuoFun” “we,” “us” or “our”) is committed to respecting the privacy rights and concerns of users of DuoFun’s mobile game application, Chief Puzzle Officer, and the associated website located at www.chiefpuzzleofficer.com (together, the Service”). As such, we have established and implemented this Privacy Statement to inform visitors to the Service of how we use and protect the information we collect through the Service. By visiting or browsing the Service, you consent to DuoFun’s collection, use, storage, deletion, transfer to the United States, and disclosure of personal information relating to you as set forth in this Privacy Statement. This Privacy Statement is effective as of the date set forth above and covers our collection, use, and disclosure of information we collect through the Service.

DuoFun is committed to complying with the EU-U.S. Privacy Shield Principles of protecting personal data. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at  https://www.privacyshield.gov/list .

This Privacy Statement answers the following questions:

·          What information do we collect about you and how do we use it?

·          Will we share your personal information with third parties?

·          What choices do you have about the collection and use of your personal information?

·          What security measures do we take to safeguard your personal information?

What Information Do We Collect About You and How Do We Use It?

Types of Information We Collect

Personal information means information that can be used to identify and contact you. The Service may collect personal information from you including your email address, name, username, password, phone number, location, photograph, social media information, credit card information, billing and shipping information, and cookies.

We may collect personal information when you create an account on the Service; email us a request to receive customer or technical support; subscribe to our newsletter; participate in Service feedback, questionnaires, surveys, or contests; or make a purchase through the Service.

How We Use Your Personal Information

We may use your personally identifiable information for all legal purposes. For example:

Technical Support: DuoFun may use your email address to contact you regarding any customer or technical support issues.

Payment Processing: If you purchase goods or services through the Service, DuoFun may need for you to provide certain financial information so that DuoFun may effect a payment transaction. As part of the payment system, DuoFun or third parties performing sales processing services on DuoFun’sbehalf, will collect, store and use non-public personally identifiable information, such as your name, address, credit card number, phone number, and your e-mail address. In addition, the payment system will also collect information regarding the actual bill payment transaction, including the date and amount paid. DuoFun will store and protect this information in the same manner that DuoFun stores and protects other personal information.

De-Personalizing Your Information

We may make your personal information non-personally identifiable by either combining it with information about other users (aggregating your personal information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information. You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your personal information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect on the Service (the “Analytical Data”). We are expressly authorized to make any commercial use of the Analytical Data, including without limitation, sharing the Analytical Data with third parties.

We may collect information on access times from users of the Service, as well.

“Do Not Track”

 

When you use the Service, we may also collect information about your online activities over time and across third-party websites or online services. Because there is not yet a consensus on how companies should respond to web browser-based or other do-not-track mechanisms, we do not respond to web browser-based do-not-track signals at this time.

Children’s Privacy

We do not knowingly collect any personal information from children under the age of 13, allow them to create accounts or use the Service. DuoFun takes children’s privacy seriously and encourages parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when on-line. If you have any concerns about your child’s personal information, please contact us at support@duofunstudios.com.

How We Will Share Your Personal Information With Third Parties

We will share the personal information we collect from you under the following circumstances:

Additional Information You Should Know About Third Parties

Please be aware that we cannot control the activities of third parties to whom we provide data, and as such we cannot guarantee that they adhere to the same privacy and security procedures as DuoFun.

 

When you click on a third party logo or URL displayed on our Service that links you to a different website, our Privacy Statement no longer applies and you must read the privacy policy of the third party to see how your personal information will be handled on their website. If you cannot find their privacy policy, then you should contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies. We are not responsible for their collection and use of your personal information.

 

Some of the privacy policies of these third-party services include:

·          Appsflyer

·          MixPanel

·          Apple App Store

·          Google Play Store

EU Privacy Shield Compliance

DuoFun specifies in contracts with third parties that handle the personal data collected by DuoFun that the personal data “may only be processed for limited and specified purposes consistent with” the purposes laid out in this Privacy Policy. Those third parties agree to provide the same level of protection as the EU Privacy Shield.

What Choices Do You Have About the Collection and Use of Your Personal Information?

 

When you provide us with personal information by using the Service, entering in your username and password into the Service, or emailing us, you consent to our collecting, using, and sharing it in accordance with this Privacy Statement.

 

Control of Your Information

 

DuoFun allows you to control the way we use personally identifying information that we might obtain. At the time you provide personal information, DuoFun may give you the option of declining any future offers or information about new products, promotions, or services. In addition, many of the “mailings” DuoFun may send you, such as newsletters, have procedures within them to cancel the receipt of any future mailings.

 

You may opt out of any disclosure of personal data to a third party or the use of data for any purpose other than the one for which it was initially collected by emailing us at support@duofunstudios.com. You must provide us with the email address or username associated with your DuoFun account and the details of your privacy request.  

 

Data Retention

 

DuoFun retains the collected data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. Thereafter, DuoFun deletes all aforementioned data in its possession within a reasonable timeframe. DuoFun does not verify the correctness of personal data.

In some cases, we may not be able to delete your personal information, and will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We take reasonable steps and appropriate measures to protect data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Please note that some data may be retained if necessary to resolve disputes, enforce DuoFun’s user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Service.

How to Correct or Delete Your Data

 

Any individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the following email address: support@duofunstudios.com. Please include your full name and email address associated with your account and a detailed description of your data request. We will respond to any request for access within 30 days.


In some cases, we may not be able to delete your personal information, and will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In exceptional circumstances, such as where the privacy of other individuals would be violated, where it may reveal trade secrets, or where the burden of expense of providing access would be disproportionate to the risks to your privacy, we may restrict such requests for access.

 

California Residents: Your California Privacy Rights

 

Under California law, our customers that are California residents may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. See the section above entitled “How We Will Share Your Personal Information With Third Parties” for more information. Furthermore, we give customers a mechanism to opt out of having their personal information disclosed to third parties for their direct marketing purposes. If you are a California resident, you may opt out of having your personal information shared with third parties and/or receiving information from DuoFun (via email) about new products, services, or promotions, by contacting us at support@duofunstudios.com. Please include your full name and username associated with your account and a detailed description of your data request.

 

International Transfers

Personal information collected on the Service may be stored and processed in the United States or any other country in which DuoFun or its affiliates, subsidiaries or agents maintain facilities, and by using the Service, you consent to any such transfer of information outside of your country.

Governing Law

This Privacy Statement is governed by, and construed under, the laws of the United States of America and the laws of the State of California, excluding its choice of law provisions.

Mediation

If you are a resident of a country outside the European Union, you agree that, in the event any dispute or claim arises out of or relating to this Privacy Statement, you and DuoFun will attempt in good faith to negotiate a written resolution of the matter directly between the parties. You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Los Angeles, California with a mutually agreed mediator in an attempt to resolve the dispute. Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorneys’ fees, even if you would otherwise be entitled to them.

Dispute Resolution for Residents of the European Union

If you are a resident of the European Union, in the event that you have any dispute or claim arising out of or relating to this Privacy Statement, you may report your claim use at support@duofunstudios.com. We will respond to your claim within 45 days.

DuoFun will expeditiously investigate and resolve any privacy complaint from any EU citizen at no additional cost to you.

If you are a resident of the European Union, in the event that you have any dispute or claim arising out of or relating to this Privacy Statement, you alternatively may report your claim to the European Union Data Protection Authorities located in your jurisdiction.

If you avail yourself of the above options but are unable to remedy your complaint, then you may file a complaint with the U.S. Department of Commerce at the following URL: https://www.privacyshield.gov/

If all of the above avenues have been exhausted, then you may seek binding arbitration governed by the Commercial Arbitration Rules and the Supplementary Procedures for Consumer Related Disputes (collectively, “AAA Rules”) of the American Arbitration Association (“AAA”), and will be administered by the AAA, except as modified below. The AAA Rules and Forms are available online at www.adr.org or by calling the AAA at 1-800-778-7879. The arbitration will take place in Los Angeles, California. If the claim being arbitrated is less than $10,000, then the party filing the arbitration may choose to have the arbitration conducted by telephone, online, and/or be solely based on written submissions. A hearing will be established according to the AAA Rules for claims in excess of $10,000.

European Privacy Shield

DuoFun complies with the EU Privacy Shield Framework regarding the collection, use, and retention of personal information from European Union member countries. DuoFun has certified that it adheres to Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.

What Security Measures Do We Take To Safeguard Your Personal Information?

The personal information that you provide to us is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure the security of such information, including data encryption and password protection measures. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the Service and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.

Notification of Changes

This Privacy Statement may change from time to time and we will post all changes on the Service. You understand and agree that you will be deemed to have accepted the updated Privacy Statement if you use the Service after the updated Privacy Statement is posted on the Service. If at any point you do not agree to any portion of the Privacy Statement then in effect, you must immediately stop using the Service.

Questions? Contact Us

If you have any questions about our privacy practices or this Privacy Statement, please contact us by email at support@duofunstudios.com or by postal mail at 11748 Willard Avenue, Tustin, CA 92782.