Last modified on June 12, 2018
We ask that you read this privacy notice carefully, as it contains important information on who we are, how and why we collect, store, use and share Personal Information. Your rights in relation to your Personal Information is included in this notice, along with how to contact us and supervisory authorities in the event you have a complaint.
Who We Are
Arbitrary Zen, LLC (“Arbitrary Zen,” “We,” or “Us”) collects, uses and is responsible for certain Personal Information about you, as part of providing the Arbitrary Zen website and mobile applications (collectively, the “Service”).
For those in the European Union, we are regulated under the General Data Protection Regulation which applies across the European Union, and we are responsible as a controller of that Personal Information for the purposes of those laws.
Personal Information We Collect
Information collected by us: In the course of providing you with the Service, we collect the following Personal Information, either automatically or when you explicitly provide it to us:
- Your IP address, browser type, and information about your gameplay and activities on the Service are collected automatically while you use the Service (your “Analytic Information”)
- Your unique Advertising ID
- Your name and email address (if you sign up for our newsletter)
Personal Information Usage
We use your Personal Information as follows:
- Your email address is used to communicate with you about Service-related issues (including receiving and responding to communications that you send us through the Service), and to send you Service-related communications about new products and services.
- Your Analytic Information is gathered and pooled with other users’ information, and used for the purposes of improving the Service, such as tracking the total number of users or visitors to the Service, their aggregate activities on theService, gameplay data and other gameplay analytics, and tracking the sites that refer visitors to Arbitrary Zen.
- Your Advertising ID is used to display personalized advertisements on the Service (see Personal Information Sharing for we share your Personal Information with for more information).
Personal Information Sharing
We share your Personal Information with certain third parties as part of our operation of the Service, whether shared by us or gathered directly by third parties through SDKs integrated into the Service. This data sharing enables us to provide you with the Service in the optimal way, such as serving you personalized, relevant advertisements within the Service.
Some of those third-party recipients may be based outside the European Economic Area. For further information, including how we safeguard your personal data when this occurs, see their individual privacy policies and the section entitled “Transfer of Your Information out of the EEA.”
We share your Personal Information with the following third parties:
Advertisements: Some of your Personal Information, such as your Advertising ID, is gathered by advertisers to display advertisements on the Service that are relevant to your interests.
Our third-party advertisers are:
- Google (AdMob)
- Twitter (MoPub)
We may add and remove advertisers from this list from time to time.
If you would like more information about online advertising and your choices about not having this information used by these companies, please see:
Analytics: We may use third party website and mobile application analytic tools on the Service, that employ cookies and other tracking methods (such as tracking pixels) to collect certain information concerning your use of the Service. These tools include:
- Google Analytics
- AOL Oath (formerly Flurry)
Newsletters: If you opt in to our newsletter, your name and email address may be shared with our newsletter provider, MailChimp.
We will share your Personal Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of Arbitrary Zen, its employees, clients, or users of the Service.
Personal Information Storage
Please note that some data may be retained if necessary to resolve disputes, enforce Arbitrary Zen user agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of the Service.
Why We Collect Personal Information
The laws in some jurisdictions require that we notify you of the lawful basis for collecting your Personal Information.
To the extent that such laws apply, we rely on the following as the lawful basis on which we collect and use your Personal Information:
Consent: At times we may collect, process, store, transfer or disclose your personal data on the basis of your implied or explicit consent.
To fulfill our contractual obligations: In order to fulfill our contractual obligations to you, we must collect, process, and store your personal data and information. For example, we may handle your personal data in this manner if you make a purchase on the Service, though generally that personal data (including payment information) is solely collected by Google, Apple, Amazon, or other platform holders when you make the purchase through them, and is governed by their privacy policies.
Furtherance of legitimate interests: We may collect, process, store, transfer or disclose your personal data in furtherance of those legitimate interests of ours which are not overridden by your interests or fundamental rights and freedoms as set forth in the applicable laws. These legitimate interests include, but are not limited to:
- Providing you with the Service
- Protecting our users, staff, and property
- Collecting information on how you use the Service in order to optimize the design and functionality of the Service
- Display personalized advertisements
- Communicating with you via e-mail for communications you have explicitly opted into (e.g., notifications about new products and services) or for communications regarding the Service (e.g., customer service and troubleshooting).
Legal compliance: We may collect, process, store, transfer or disclose your personal data to comply with our legal obligations.
Depersonalized Information: We may make your Personal Information non-personally identifiable by either combining or aggregating it 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 and is used to analyze usage and improve the Service.
Children’s Privacy: We do not knowingly collect any Personal Information from children under the age of 13, allow them to sign up for newsletters, make purchases, or use the Service. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16. Arbitrary Zen 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 online.
Personal Information Transmission
Under the laws of some jurisdictions, including the General Data Protection Regulation in the EEA, you have a number of important rights with regard to your Personal Information.
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
- If we are processing your personal data for reasons of consent or to fulfill a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
- If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
- You have the right to ask us to stop using your information for a period of time, if you believe we are not doing so lawfully.
- Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
Personal Information Security
We have taken steps to put appropriate security measures in place to prevent Personal Information from being accidentally lost, or used or accessed in an unauthorized way.
For example, we limit access to your Personal Information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We use SSL encryption and other technologies to keep data safe when we transfer and store Personal Information.
How To Complain
We hope that we can resolve any questions or concerns you raise about our use of your Personal Information. Please contact us via the methods listed below in the section entitled “How To Contact Us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.
If you are an EU citizen, the General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
How To Contact Us
If you wish to contact us: