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1. INTRODUCTION
 

1.1 Unless specified otherwise in this privacy policy, capitalized terms used in this privacy policy shall have the same meanings given to them in the Hidden Secrets Terms of Service (at www.hiddensecretsapp.com/terms-of-service)
 

1.2 Protecting your privacy (and the privacy of your authorized Minor(s), if any) is important to Hidden Secrets Studios Limited (referred to as Hidden Secrets, we, us and our). With this in mind, we’re providing this privacy policy to explain our practices regarding our processing of personal information (information).  This privacy policy applies in respect of the Platform, and does not apply to any third party websites, services, or applications, even if they are accessible through the Platform.
 

1.3 Any information that is collected via our Platform is covered by the privacy policy in effect at the time such information is collected. We may revise this privacy policy from time to time. If we make any material changes to this privacy policy, we’ll notify you of those changes by posting them on the Platform or by sending you an email or other notification, and we’ll update the “last updated date” above to indicate when those changes were made.
 

1.4 If you have authorized a Minor to access the Platform (see the Terms of Service), you must ensure that the relevant Minor has read and understands this privacy policy, all rights available to the Minor in respect of his or her information, and the fact that  this privacy policy will apply to all of the Minor’s information provided to, or collected by or on behalf of, Hidden Secrets. 

 

2. CATEGORIES AND USE OF INFORMATION

2.1 Account information

When you start engaging with our Platform, we collect information such as device model, OS and OS version.  Additionally, our Game creates a randomized Unique Device ID (UDID).  That UDID is unique to Hidden Secrets and allows us to associate all activities to a single device for sake of saving game progress and validating any prize claims.

 

2.2 Gameplay Information​

When you engage in the Platform, we will process:
 

1. information on how you use the Platform (such as the web pages that were visited prior to accessing the Platform; the pages or features of the Platform that were browsed and the time spent on those pages or features; search terms and the links on the Platform that were clicked on; and other group statistics); and

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2. information that your device sends (like a device identifier, user settings, country, language, browser type, operating system, and location information (when location services are turned on),
 

and combine that information with the UDID. This information is used to improve gameplay and the Platform, to personalize the Platform for you, and for marketing purposes including direct marketing.

 

2.4 Email Subscription​

If you elect to subscribe to our mailing list, we will collect your email address for the purposes of:
 

1. periodically sending you free newsletters and emails that directly promote the Platform; and

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2. creating “Lookalike Audiences” and to customize content and advertising on social media websites such as Facebook.
 

You have the option to opt out of receiving direct marketing communications from us. If you do not wish to continue to receive direct marketing communications from us you should opt out by clicking on the “unsubscribe” link in any email communications that we might send you.  Please note that some features of the Platform may involve us providing suggestions for additional services we offer, through the functionality within the Platform.
 

2.5 Website Information Collected Using Cookies and other Web Technologies

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Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information on our website. Whether this information is personal to you will depend to what extent the technology can individuate you, in the sense that you are singled out and distinguished from all others.

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1. “Cookies” are small text files that are placed on your hard drive by a web server when you access our website. We may use both session Cookies and persistent Cookies to identify that you have logged in to the Platform and to tell us how and when you interact with the Platform. We may also use Cookies to monitor aggregate usage and web traffic routing on the Platform and to customize and improve the Platform. Session Cookies are deleted when you (or your authorized Minor) log off from the Platform and close the browser.  Persistent Cookies remain on your computer and will identify how you use the Platform over time. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you (or your authorized Minor) may not be able to access all portions or features of the Platform. Some third-party service providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive.

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2. “Web Beacons” (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on the Platform for several purposes. For example, we may use Web Beacons to deliver or communicate with Cookies, to track and measure the performance of the Platform, to monitor how many visitors view our Platform, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an email). We use these web beacons, such as Facebook Pixel, to customize content and advertising, to provide social media features and to analyze traffic to our website.

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3. LAWFUL BASIS FOR PROCESSING

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Please note that if we are unable to process information in the manner outlined in this privacy policy, then the Platform may suffer from reduced functionality, and certain features may be disabled.

 

3.1 Performance of a Contract

1. In respect of the processing of information of your information for the purposes of providing the Platform, creating a UDID to associate all activities to a single device for sake of saving game progress and validating any prize claims, and discovering if you have falsified your claim to any such prizes, such processing is necessary for the performance of the contract between you and us.

 

3.2 Legitimate interests

1. In respect of all other processing of information detailed in this privacy policy, such processing is necessary for the purposes of a legitimate interest pursued by us, and we have assessed that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject to whom the information relates.

2. If you are based in the European Union you have the right to object to the way we processes your information where the processing is based on legitimate interests. For more information see “Rights of EU based persons” section below for further details.

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4. INFORMATION THAT WE SHARE WITH THIRD PARTIES

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We will not share any of your personally identifiable information that we have collected from or regarding you except as described below:

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4.1 Information Shared with Professional Advisors and Service Providers

We may share information with our professional advisors (including in connection with any audits, professional advice, research, or process and product improvements) on a need to know basis, and with a range of third party processors to assist in providing the Platform (including website hosting, data storage, information technology and related infrastructure, Platform maintenance, e-mail delivery, social media, advertising and analytics partners). We will use reasonable efforts to obtain assurances from any such third parties that they will safeguard information consistent with this privacy policy (which may include contractual obligations).​
 

4.2 Information Disclosed in Connection with Business Transactions

If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your information, may be disclosed or transferred to a third party acquirer in connection with the transaction. In the event of such a transaction, we will give you notice of the transaction and the opportunity for a period of 30 days to refuse disclosure or transfer of your information to the third party acquirer in connection with the transaction.
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4.3 Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you that is in our possession or control to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to identify and stop any activity that we consider illegal, unethical, or legally actionable activity.

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5. YOUR CHOICES

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We offer you choices regarding the collection, use, and sharing of your information and we’ll respect the choices you make. Please note that if you decide not to provide us with the information that we request, you may not be able to access some or all of the features of the Platform.

 

5.1 Access and Correction of Information​

1. You have the right to seek access to information which we hold about you and to correct that information if it is incorrect.

2. If you wish to exercise your rights, please contact us using the contact information below. We may require you to provide verification of your identity.

3. Please note that in certain circumstances we may withhold access to your information where we have the right to do so, for example, where disclosing the information may reveal the identity of a third party.

 

5.2 Rights for EU-Based Persons​

Under the GDPR, if you are based in the European Union you have the right to:

1. access and correct your information.

2. in certain circumstances, have your information erased.

3. restrict the processing of your information.

4. move, copy or transfer your information easily for your own purposes across different services in a safe and secure way.

5. object to processing where we rely on our legitimate interests as the basis for processing.

6. withdraw your consent to our processing of your information where your consent is being relied on by us.

 

If you wish to exercise your rights please contact us at hello@hiddensecretsapp.com to submit the request.

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6. KEEPING YOUR INFORMATION

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Following termination or deactivation of your account, Hidden Secrets, its clients, affiliates, or service providers may retain information (including your profile information) and user content for a commercially reasonable time period for backup, archival, and/or audit purposes. If you have any questions about termination or deactivation of your account, please contact us directly at hello@hiddensecretsapp.com.​

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7. RESPONDING TO DO NOT TRACK SIGNALS

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The Platform does not have the capability to respond to “Do Not Track” signals received from various web browsers. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.org.
 

8. THE SECURITY OF YOUR INFORMATION

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We take appropriate GDPR approved administrative, physical, and electronic measures designed to protect the information that we collect from or about you or your authorized child from accidental or unlawful destruction, accidental loss or unauthorized access, use, modification, interference, or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

 

9. INTERNATIONAL TRANSFER

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Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside New Zealand and choose to provide your information to us, we may transfer your information to New Zealand and process it there.  For persons based in the European Union, please note that the appropriate safeguard in place for such a transfer is an adequacy decision under Article 45 of the GDPR. Whenever we transfer your information outside of the jurisdiction in which you are located, we ensure that appropriate safeguards are in place in relation to its security. You may request us not to transfer your information to New Zealand, but if you do so, we may not be able to provide some or all of the Platform to you.

 

10. QUESTIONS?

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Please contact us at hello@hiddensecretsapp.com if you have any questions about our Privacy Policy, or if you wish to make a complaint about our collection, use, or disclosure of your information under this privacy policy. We will use our reasonable endeavours to address any complaint you may have as soon as possible.