Inochi Project Privacy Policy

Last updated March 2017

Inochi Project plc, including its affiliates (“Inochi”), collects, stores, and uses your personal information as a data controller in connection with and in order to provide and develop our products, mobile applications, services and websites (together “Inochi Services”) according to this privacy policy (“Privacy Policy”).

For questions and information about Privacy Policy and data subject’s rights, please contact us at privacy@inochiproject.com.

For information about our privacy practices related to data from children, please see “Special Note About Children’s Privacy” below.

All Inochi Services are governed by this Privacy Policy and by using or accessing a Inochi Service You give consent to the processing, use and disclosure of your data.

Please do not install or use the Inochi Services if you do not agree to this Privacy Policy.

Inochi reserves the right to modify this Privacy Policy. Your continued use of the Inochi Services will signify your acceptance of the changes to this Privacy Policy.

1. How We Collect Your data

Here are a non exhaustive list of examples of likely situations when you make personal data available to Inochi: (i) by using Inochi ’s mobile apps or visiting our websites, (ii) registration for Inochi Services; (iii) subscribing to newsletters; (iv) purchasing a product or services within the app (or “in-app purchase”); (v) using “tell a friend,” “email this page,” or other similar features; (vi) requesting technical support; and (vii) otherwise through use of Inochi Services where personal data is required for use and/or participation.

The data we process on you may include, but is not limited to: email address, device ID, IP-address, user names and passwords.

Inochi may supplement your data with data received from third parties in connection with demographic, advertisement, market and other analytics surveys or services.

Some third party services such as Twitter and Facebook may also provide us with information from your accounts with your permission.

By playing an Inochi Service through a social network or other third party platform or service or by connecting to such a third party network, platform or service via an Inochi Service, you are authorizing Inochi to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the social network or other third party platform could provide to Inochi through the social network/third party platform Application Programming Interface (API) based on your settings on the third party social network or platform. Your agreement takes place when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, “accept” or “allow” (or similar terms) a Inochi Service through a social network, or other third party platform or service.

2. Ad Serving Technology

Inochi reserves the right to use and disclose the collected, non-personal data for purposes of advertising by Inochi or Inochi’s partners and contractors.

Inochi may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services.

Inochi or third parties operating the ad serving technology may use demographic and geo-location information (for more information regarding use of Location Data see below Section 3) as well as information logged from your hardware or device to ensure that relevant advertising is presented within the Service.

Inochi or third parties may collect and use data, for such purposes, including but not limited to, data such as IP address, Device ID, MAC address, installed software, application usage data, hardware type, Operating System information, browser information, unique identifiers in browser cookies, Flash cookies, and HTML5 local storage, Internet and on-line usage information and in-game information. The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.

Inochi may display to you behaviourally targeted advertising. If you wish to “opt out” of certain targeted advertising, please visit www.youradchoices.com and/or www.networkadvertising.org. Please note that the links above may not reach all Inochi’s advertising partners and certain behaviourally targeted advertising may still be displayed to you. If you want to be certain that no behaviourally targeted advertisements are displayed to you, please do not use or access the Services.

Some services may include the use of in-game advertisements or brand placement. Such ads or sponsorships will be noted as such within 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

To the extent Inochi makes location enabled Inochi Services available and you use such Inochi Services, Inochi may collect and process your location data to provide location related Services and advertisements. For example, some add-ons or offers may be available at dedicated locations. The location data is processed and stored only for the duration that is required for the provision of the location related Services.

Inochi may use, depending on the service (1)IP-based location based on the IP address presented by the end-user, (2) fine geo-location data based on coordinates obtained from a mobile device’s GPS radio, or (3) coarse, network-based geo-location data based on proximity of network towers or the location of WiFi networks.

Your fine, GPS-based geo-location is not accessed without your consent. Notwithstanding Inochi’s partners who are providing location related parts of the Service, Inochi will not share your GPS geo-location with third parties without your consent. To the extent Inochi makes available GPS geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously.

4. Analytics

Inochi uses your information to perform its own analytics and to enable analytics provided by third parties. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving products and services, personalizing content, providing advertising, and making recommendations. Inochi may also use third-parties, such as a Mixpanel in order to develop and analyse use of the Services. For more information about Mixpanel and its services please see mixpanel.com.

5. Disclosure and Transfer of Personal Data

Personal data may be disclosed to third parties including third parties located outside the European Union or the European Economic Area in accordance with applicable legislation and this Privacy Policy. Inochi may use third parties to collect and process personal data on Inochi’s behalf and in according to Inochi’s instructions. Inochi is not liable for the acts and omissions of these third parties, except as provided by mandatory law.

6. Data Retention and Correctness

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

Please note that some data may be further retained if necessary to resolve disputes, enforce Inochi 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, local shared objects, hardware-based device identifiers, Operating System-based identifiers, clear GIFs and web beacons. Inochi treats information collected by cookies and similar technologies as non-personal data.

Cookies: A “cookie” is a small file stored by your browser when told to do so by a website. Typically websites place a number of different cookies on an end-user’s machine. Some of the cookies are “1st Party,” from the website itself, and others are “3rd Party,” belonging to advertising and analytics entities or social networks. Inochi’s cookies do not include personal data and are typically used to quickly identify your device and to “remember” your browser during subsequent visits for purposes of functionality, preferences, and website performance. 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.

Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image (often not visible to the end-user) that allows Inochi to count users who have visited certain pages or viewed certain advertisements. Additionally, e-mails and other electronic communications Inochi sends to you may contain pixel tags that enable Inochi 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 Inochi is not liable for any such third parties’ use of your personal data.

Certain Inochi Services that Inochi may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the Services with a gaming console ID, social networking ID, or gaming network account. In connection with such use, certain personally identifiable user and/or membership data may be transferred automatically to and from Inochi.

Inochi may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of Inochi ’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data.

9. Safeguards

Inochi follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Inochi’s possession.

10. Other

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 will become public information, and there is no expectation of privacy or confidentiality with respect to that data. Inochi may store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy.

11. Special Note about Children’s Privacy

Inochi does not knowingly collect personal information from children under 13 years of age. If Inochi learns that Inochi has inadvertently gathered personal data from children under 13 years of age, Inochi will take reasonable measures to promptly delete such personal data from Inochi ’s records.

Inochi understands the need to provide extra privacy protections to users who are children. To that end, features and services such as social networking plug-ins, behaviorally targeted advertising, and collection of data for the purpose of building user profiles are not available to users under 13. Inochi also does not allow our third party partners who engage in such practices to access personally identifiable data from users under 13.

Inochi and its partners do collect non-personally identifiable data from children. This includes, for example, collection of IP-based geolocation data to ensure that the product, service or features served comply with applicable laws of that nation.

Inochi and its partners also collect data to assess general information about the use of products, such as the number of visitors to our sites and services and which sections of a site or service are popular. Inochi also uses this data to provide contextually-relevant advertising to users, to prevent users from seeing the same ad repeatedly, and to allow users to personalize their experience on the site or service (for example, to save a high score in a game). Inochi and its partners may also use cookies, pixels, hardware-based identifiers, Operating System-based identifiers, and software-set identifiers, to manage and measure the performance of advertising.

Please note that Inochi’s partners may have their own policies related to tracking technologies for analytics and ad-serving purposes. While Inochi requires that companies comply with Inochi’s privacy policy before Inochi allows those companies to access our sites and services, Inochi does not actually control third-party data collection and use. If you have additional questions about Inochi’s Privacy Practices related to children under the age of 13, please contact us at privacy@inochiproject.com.

12. Further information

This Privacy Policy is governed by English law and subject to the exclusive jurisdiction of the English courts.