TOTAL ECLIPSE P.C.

 

PRIVACY POLICY

[FASHION GETAWAY]

 

 

1.   Our commitment to privacy

Protecting your privacy is a top priority for us. Total Eclipse PC (“Total Eclipse”) is a Private Company with registered offices at 28 Verginas Street, Pylea, Thessaloniki, 54250, Greece. Fashion Getaway is a mobile gaming application (“App”) developed, published, and owned by Total Eclipse.

 

By using this App and our related services (“Services”), you are accepting the practices described in this Privacy Policy. Unless stated otherwise, this document only deals with the use and communication of data collected by Total Eclipse.  Those Privacy Policy provisions are part of our TOS.

 

2.   Compliance with Child Online Privacy Protection Act (COPPA)

We do not knowingly contact, or collect personally identifiable information from children under the age of 13. If you believe that we have inadvertently collected such information, please contact us at privacy@totaleclipsegames.com and we will attempt to obtain parental consent, or effectively remove said information. 

 

Our App is in compliance with COPPA’s terms and policies. Specifically:

-       Fashion Getaway has as its primary audience young teens and adult. However, we accept that the App is directed towards and might appeal to, children younger than 13.

-       Fashion Getaway collects age information in order to comply with COPPA legislation and personalise the user experience.

-       We do not collect any personal information from any user prior to collecting age information.

-       For users who identify themselves as under age 13:

o   We only collect Persistent Identifiers as defined in §16 C.F.R. 312.2.7, [1] and no other personal information.
(7) A persistent identifier that can be used to recognize a user over time and across different Web sites, or online services. Such persistent identifiers include, but are not limited to, a customer number held in a cookie, an Internet Protocol (IP) address, a processor or device serial number, or a unique device identifier;

o   We collect Persistent Identifiers to improve our Services and perform analytics related to the Services.

o   We do not use Persistent Identifiers for behavioral advertising purposes that would recognize a user over time and across different websites or online services.

o   The Persistent Identifiers that we collect fall under the exception of “Support for the internal operations of the Website or online service” as defined in §16 C.F.R. 312.2.10. [2]

3.   What information is collected

a)    Persistent Identifiers

Like many other game developers, we are using Persistent Identifiers to support our App’s internal operations and improve our players’ experience. Such Identifiers help us personalise the content that you experience, and securely authenticate you as our player, across the devices the game is installed. This authentication also assists us with synchronising your gaming content across various devices. These Identifiers will not be used to contact you, or perform behavioural advertising.

Identifiers that we may use are:

b)    Non-personal data                                                                                                  

We may use third party analytical software and tools, to collect and use non-personal data. Such data consists of statistical and other analytical information collected on an aggregate basis of all users of our App. 

 

The type of non-personal data collected and used is “aggregated game usage data:” information that cannot be used to identify or contact you in any way, and is used only for analytical and statistical purposes.  We may use the collected data to analyse usage of the App and further enhance our services to you. We retain the right to use and disclose such collected non-personal data for publicity purposes.

c)     Geolocation information

We cannot track precise geolocation information of our users, such as street name and number. Coarse location information to city, or country level, might be available to us through the IP address, and will only be used for analytical and statistical purposes.

 

Other than the above stated personal information, we do not collect, or gather, any user or device data which could be used to identify or personally contact you in any way.

d)    Year of birth information

Upon launching the App for the first time, the user is required to enter his/her year of birth. No precise date or month details are requested. Since our app may be used by children, we are requesting the year of birth to better personalize the App for younger users and comply with regulations set by various stakeholders, such the FTC and Apple.  

4.   How the information is used

a)    Analytics

We are currently using third-party services for analytics purposes. Analytics companies may access anonymous data such as game usage information to help us understand how our services are used.

b) Advertising

From time to time we might also serve advertisements through the App. Any advertising effort will be strictly contextual.  During contextual advertising, we do not submit any identifiable information to third parties, which might be used to track you across our other Apps or Services.

 

5.   How the information is stored

Information we collect may be stored or processed on computers located in any country where we operate, in order to improve our Website’s and App’s user experience. If you wish this information be permanently deleted from our database when you stop using our Services, please notify us at privacy@totaleclipsegames.com .

6.   Legal requests

We cooperate with law enforcement authorities, as well as other third parties, to take legal action, protect and manage intellectual property rights, and prevent fraud. In response to a verified request by law enforcement authorities, or other government officials relating to a criminal investigation or alleged illegal activity, we can, and you authorize us to, disclose your Persistent Identifiers, Website or App use history, and any other personal information that we gather as described above, with or without a subpoena. Without limiting the above, we will not disclose your personal information to any law enforcement authority or other governmental officials without a subpoena or court order, except when we believe in good faith that the disclosure of information is necessary to protect our rights, enforce our policies, respond to claims that your use of our Services violates Total Eclipse’s policies or rights of others, or protect anyone’s rights, property, or safety.

7.   How we protect your information

The privacy and protection of your personal information is important to us. We do not make any of the information we collect from you available to third parties for their marketing purposes. If however, we share your information with third parties as indicated at par. 6, such action will be disclosed and you will be notified. Please note that no information transmitted over the internet can ever be deemed fully confidential or subject to non-disclosure, and as such you transmit information at your own risk.

 

We do not tolerate spam. To report Total Eclipse-related spam please contact us at support@totaleclipsegames.com. You may not use our communication tools to send spam or otherwise send content that would violate our TOS. We may check for spam, viruses, phishing attacks, and other such malicious activity, or illegal and prohibited content of the Website and App, but we will not permanently store messages sent through these tools.

 

Total Eclipse does its utmost to secure communications and data storage in order to protect the confidentiality of your information against loss and interception by third parties. However, it is important to know that there is no zero-risk against loss or interception by others of your data.

8.   Third party terms and conditions

Please be aware that your access and ability to play Fashion Getaway may be subject to certain third party terms and conditions and privacy policies – including but not limited to application stores, mobile software platforms, on-line gaming platforms and payment providers. By agreeing to our privacy policy you recognize and agree that Total Eclipse is not liable for any such third party terms and conditions, or their use of your personal data.

9.   Links to external applications or websites

Total Eclipse may link – through advertisement to third party websites or games/applications. Be aware that third-party websites or games/applications are not under the administration, sponsorship, or affiliation of Total Eclipse. Links to any external application or website will be identified as such, and Total Eclipse will not be responsible for the privacy policies and data retention practices of others.

10.                 Protection Measures

We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes utilizing Secure Sockets Layer (SSL) software, which encrypts the personal information you share, and stores your information in encrypted form behind a firewall designed to block access to parties outside our network. However, no security or encryption method can be guaranteed to protect information from hackers or human error.

11.                 Consent

By using our App, you consent to the collection and use of your information as described in this Privacy Policy and our TOS.

12.                 Applicable Law

Total Eclipse respects your right to privacy and complies with its obligations with the laws of Greece and particularly the law regarding the Protection of Individuals and more specifically the Processing of Personal Data (Data Protection Act) (Law 2742/1997, Law 3471/2006).

13.                 Changes

In the case that Total Eclipse modifies its Privacy Policy, those changes will immediately be posted on its Website. Any such changes will take effect thirty days (30) from the time they’re posted, unless otherwise stated in the change provision. E-mail notification will be sent to users who request it.

14.                 Contact us

You may contact us directly by sending us an e-mail at support@totaleclipsegames.com. You may also use the ‘report an issue’ option in our App to contact us. In this case, your device information will be automatically included in your email. This ensures better support for your issue. Each time you report an issue or you directly send an e-mail, an e-mail is generated with you as the sender and Total Eclipse Customer Support Team as the recipient. Any identifiable device information will be clearly visible in the e-mail’s body, and can be edited or removed under your own discretion. The e-mail will only be sent if you choose to do so. We do not offer customer support to users under 13 years of age. If we become aware that a user under the age of 13 has contacted us, we will use COPPA’s one-time only request exception to answer the customer’s query. We will then proceed to delete the customer’s contact details.

 

Please note that whenever you contact Total Eclipse Customer Support through this feature, you make your personal data available to us. This is data that identifies you, or can be used to identify or contact you, and may include your name, address, e-mail address, and user IP addresses in cases where such information has not been deleted, clipped or anonymised. We collect this information, only if you voluntarily submit it to us.  Data is not transferred, handed in, or sold to any third parties. 

 

Last updated: March 12th, 2014



[1] http://www.ecfr.gov/cgi-bin/text-idx?SID=4939e77c77a1a1a08c1cbf905fc4b409&node=16:1.0.1.3.36&rgn=div5#16:1.0.1.3.36.0.32.2

[2] http://www.ecfr.gov/cgi-bin/text-idx?SID=4939e77c77a1a1a08c1cbf905fc4b409&node=16:1.0.1.3.36&rgn=div5