Privacy Policy

Last updated: 8 April 2013
Startled Monocle Privacy Policy
Startled Monocle has adopted this privacy policy (“Privacy Policy”) to explain how Startled Monocle collects, stores, and uses the information collected in connection with Startled Monocle’s products, services and websites including, but not limited to Startled Monocle’s Smash Fort and Mad Agents games (together “Services”).
Should you have any questions relating to this Privacy Policy, please contact us at info@startledmonocle.com.
BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES. Startled Monocle reserves the right to modify this Privacy Policy at reasonable times, so please review it frequently. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

Non-personal data
For purposes of this Privacy Policy, “non-personal data” means information that does not directly identify you. Additionally, non-personal data means “aggregate” and “de-personalized” information, which is data Startled Monocle collects about the use of Startled Monocle Services, from which any personally identifiable data has been removed.
Startled Monocle may use tools or third party analytical software to automatically collect and use certain non-personal data that does not directly enable Startled Monocle to identify you. The types of non-personal data Startled Monocle may collect and use include, but are not limited to: (i) device properties, including, but not limited to IP address, Media Access Control (“MAC”) address and unique device identifier or other persistent or non-persistent device identifier (“Device ID”); (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) geographical data such as zip code, area code and coarse location; (v) game progress, time used playing, score and achievements; (vi) other non-personal data as reasonably required by Startled Monocle to enhance the Services and other Startled Monocle products and services.
Startled Monocle may use Flurry analytics tool in order to develop and analyze use of the Services. If you wish to opt-out from Flurry analytics, please follow this link: http://www.flurry.com/resources/privacy.html.
Startled Monocle may use and disclose to Startled Monocle’s partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, advertisement serving, managing and providing the Services and to further develop the Services and other Startled Monocle services and products.
You recognize and agree that the analytics companies utilized by Startled Monocle may combine the information collected with other information they have independently collected from other services or products relating to your activities. These companies collect and use information under their own privacy policies.
Startled Monocle may supplement your personal and non-personal data with data received from third parties in connection with demographic, advertisement, market and other analytics surveys or services.

Ad Serving Technology
Startled Monocle reserves the right to use and disclose the collected non-personal data for purposes of advertisement by Startled Monocle or Startled Monocle’s partners and contractors. Startled Monocle may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services. Startled Monocle or third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service. Startled Monocle or third parties may collect and use data for this purpose including, but not limited to IP address (including but not limited to for purposes of determining your coarse location), Device ID, MAC, software, applications, hardware, browser information, 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.
You recognize and agree that the advertising companies who deliver ads for Startled Monocle may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies are integrated into Services; if you do not want to be subject to this technology, do not use or access Services. Although Startled Monocle takes commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, Startled Monocle does not have access to or control of third party technologies.
Startled Monocle may display to you behaviorally targeted advertising. If you wish to “opt out” of certain targeted advertising, please visit http://www.youradchoices.com and/or www.networkadvertising.org. Please note that the links above may not reach all Startled Monocle’s advertising partners and certain behaviorally targeted advertising may still be displayed to you. If you want to be certain that no behaviorally targeted advertisements are displayed to you, please do not use or access 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.

Location Data
To the extent Startled Monocle makes location enabled Services available and you use such Services, Startled Monocle 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. Startled Monocle may use various technologies to determine location, such as GPS, Wi-Fi or other network-based data such as IP address. Your GPS geo-location is not accessed without your consent. Notwithstanding Startled Monocle’s partners who are providing location related parts of the Service, Startled Monocle will not share your GPS geo-location with third parties without your consent. To the extent Startled Monocle makes available GPS geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously. Please note that Startled Monocle may share your anonymous coarse location with its partners.

Personal Data
For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual.
Likely situations when you make personal data available to Startled Monocle include, but are not limited to: (i) registration for Services, contests and special events; (ii) accessing Services using a third party ID, such as social networking sites or gaming services; (iii) subscribing to newsletters; (iv) using “share video with a friend” or other similar features; (v) requesting technical support; and (vi) otherwise through use of Startled Monocle Services where personal data is required for use and/or participation.
The types of personal data may vary depending on the type of activity you are engaged in. The personal data Startled Monocle may collect, process and use may include, but are not limited to your name, screen/nick name, Startled Monocle Services’ or third party service ID, e-mail address, phone number, photo or other image, birthdate, sex, address, friend connections, avatar image, credit card information, shipping information; and location (only if directly identifiable to you, otherwise Startled Monocle treats location as non-personal data).
Startled Monocle may use personal and non-personal data, both individually and combined together, for purposes of analyzing usage of the Services, providing customer and technical support, managing and providing Services (including managing advertisement serving), customizing Startled Monocle’s communications and to further develop the Services and other Startled Monocle services and products. Startled Monocle may combine non-personal data with personal data.
Startled Monocle may use your personal data to send messages to you with informative and/or commercial content about Startled Monocle’s services or third party products and services Startled Monocle thinks may be of interest to you, such as new features and services, special offers and updated information.
Please note that certain features of the Services may be able to connect to your social networking sites to obtain additional information about you. In such cases, Startled Monocle may be able to collect certain information from your social networking profile when your social networking site permits it, and when you consent to allow your social networking site to make that information available to Startled Monocle. This information may include, but is not limited to, your name, profile picture, gender, user ID, email address, your country, your language, your time zone, the organizations and links on your profile page, the names and profile pictures of your social networking site “friends” and other information you have included in your social networking site profile. Startled Monocle may associate and/or combine as well as use information collected by Startled Monocle and/or obtained through such social networking sites in accordance with this Privacy Policy.

Disclosure and Transfer of Personal Data
Personal data may be disclosed in accordance with applicable legislation and this Privacy Policy.
Startled Monocle may hire agents and contractors to collect and process personal data on Startled Monocle’s behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Startled Monocle. These agents and contractors may not use your personal data for their own marketing purposes. Startled Monocle may use third party service providers such as e-mail service providers, data analyzers and business intelligence providers. Startled Monocle has the right to share your personal data as necessary for the aforementioned third parties to provide their services for Startled Monocle. Startled Monocle is not liable for the acts and omissions of these third parties, except as provided by mandatory law.
Startled Monocle may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Startled Monocle to legal liability. Startled Monocle may also disclose your personal data to third parties when Startled Monocle has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Startled Monocle’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Startled Monocle believes that such disclosure is necessary to protect Startled Monocle’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Startled Monocle. To the extent permitted by applicable law, Startled Monocle will make reasonable efforts to notify you of such disclosure through Startled Monocle’s website or in another reasonable manner.

Data Retention and Correctness
Startled Monocle retains the data collected pursuant to this Privacy Policy 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 if the collected data is no longer needed for purposes specified in this Privacy Policy, Startled Monocle deletes all aforementioned data in its possession within a reasonable timeframe. Startled Monocle does not verify the correctness of personal data.
Irrespective of the above, Startled Monocle may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Startled Monocle user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

Cookies, beacons and tracking
The Services may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. Startled Monocle treats information collected by cookies and similar technologies as non-personal data.
Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user’s computer. Startled Monocle’s cookies do not include personal data and are typically used to quickly identify your device and to “remember” you. 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.
Flash cookies & HTML5: Startled Monocle may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember your settings to personalize the look and feel of the Services. Locally shared objects only collect data in the aggregate. You may prevent locally shared objects from being placed by disabling locally stored objects in your browser or visit www.adobe.com. Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies.
Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image that allows Startled Monocle to count users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications Startled Monocle sends to you may contain pixel tags that enable Startled Monocle to track your usage of the communication, including whether the communication was opened and/or what links were followed, if any.

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 privacy policies, including but not limited to application stores, map data providers, mobile software platforms, online gaming platforms, social networking services and payment providers. You recognize and agree that Startled Monocle is not liable for any such third party terms and conditions and their use of your personal data.
Startled Monocle may in its discretion make available links through advertisements or otherwise enable you to access third party products or services. Please note that, while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by Startled Monocle. Startled Monocle is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that Startled Monocle is linking to those products or services does not constitute our sponsorship of, or affiliation with, those people or companies.
Startled Monocle may from time to time make available Startled Monocle’s partners’ services, such as sweepstakes or polls and such services may require you to disclose personal data in order to register for and access such services. Such services will reasonably identify the partners at the point of where you are required to disclose personal data. If you at that point choose to disclose your personal data, such personal data may be transferred directly or via Startled Monocle to such third parties and will be subject to the privacy policy and practices of such third parties. Startled Monocle is not responsible for the privacy practices and policies of such third parties and, therefore, you should review the privacy practices and policies of such third parties prior disclosing any personal data in relation to such services.
Please note that certain Services that Startled Monocle 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. When you register to join or use the Services from a third-party gaming or social networking system, certain personally identifiable user and/or membership data may be transferred automatically to and from Startled Monocle and you hereby consent to the processing, using, combining, disclosing and retaining of such data in accordance with this Privacy Policy by Startled Monocle.

Safeguards
Startled Monocle follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Startled Monocle’s possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in Startled Monocle’s possession. Personal data collected by Startled Monocle is stored in secure operating environments that are not available to the public. To prevent unauthorized online access to personal data, Startled Monocle maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite Startled Monocle’s reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.

Other
Please be aware of the open nature of certain social networking and other open features of the Services Startled Monocle may make available to you. 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 is public information, and there is no expectation of privacy or confidentiality. Startled Monocle is not responsible for any personal data you choose to make public in any of these forums.
If you are under 13 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access the Services. Startled Monocle encourages parents and/or guardians to play an active role in their children’s online experience at all times. Startled Monocle does not knowingly collect any personal information from children under 13 years of age and if Startled Monocle learns that Startled Monocle has inadvertently gathered personal data from children under 13 years of age, Startled Monocle will take reasonable measures to promptly erase such personal data from Startled Monocle’s records.

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