Super Free Games Inc., its subsidiaries and affiliated companies (“Super Free” or “we”) provide this Privacy Policy to inform you of our policies and procedures regarding our collection, use and disclosure of information. Except as explicitly provided herein, this Privacy Policy applies only to information we receive from users of (i) the website located at https://superfreegames.com (the “Site”), including any services, features and content accessible or downloadable from the Site, and (ii) any other Super Free application, service or product licensed, downloaded or otherwise accessed by such users through third party websites or sources ((i) and (ii) collectively, the “Service”). For purposes of data protection laws, Super Free Games Inc., PO Box 84, San Francisco, CA 94104-9991, is the “data controller” of your information.
By registering for a user account and/or accessing or using the Service, you agree to the terms and conditions of this Privacy Policy, and you consent to the collection, use and disclosure of your information by Super Free Games in accordance with the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not provide us with any information and do not use the Service.
Super Free Games reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time (for example to reflect updates to the Service or to reflect changes in the law). If we make a material change to the Privacy Policy, we will provide you with appropriate notice and will seek your consent to the updated Privacy Policy in accordance with applicable legal requirements. Please check this Privacy Policy periodically for those changes. Your continued use of the Service after the posting of changes constitutes your binding acceptance of such changes.
We obtain information about you when you use or otherwise access the Service. Please note that we need certain types of information so that we can provide the Service to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use the Service. Information We Collect From You We collect information you provide directly to us. For example, you may provide us with information through your:
The types of information we collect directly from you include:
Information We Collect From Third Parties We may collect information about you or others through our affiliates or through non-affiliated third parties. For example, you may be able to register for an Account through a social networking account. If you access the Service through a social media account, you may allow us to have access to certain information in your social media profile. This may include your user ID, name, email, gender, birthday, current city, profile picture URL and the user IDs of your friends who have also connected with our applications. We may also cache data we receive from the Facebook APIs to improve our user experience. Social networking sites have their own policies for handling your information. For a description of how these sites may use and disclose your information, including any information you make public, please consult the sites’ privacy policies. We have no control over how any third-party site uses or discloses the personal information it collects about you. We may also collect information about you from non-affiliated third parties for fraud or safety protection purposes, or for marketing purposes. For example, we may receive information about your use of products/services offered by our advertising partners. We may collect also collect information about you, such as your name or email address, from third party websites or other sources from which you download or access Super Free Games applications, services or products that also make up part of the Service. We likewise may combine information that we collect from you through the Service with information that we obtain from such third parties and information derived from any other products or services we provide. Information We Collect Automatically Device/Usage Information: We and our third-party service providers may use cookies, web beacons, and other tracking technologies to collect and store information about your use of the Service. As described further below, we may collect and analyze information including, but not limited to: (1) device type; (2) operating system and version; (3) carrier provider; (4) IP address; (5) Media Access Control (MAC) address; (6) International Equipment Mobile ID (IMEI); (7) whether you are using a point package; (8) the game version; (9) the device’s geo-location; (10) language settings; and (11) a unique device ID. In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your Account profile information to enable us to move your information to a new device at your request. In addition, it may be used to link a character with which you play our games to your username on the Forums. Log Data, Cookies and Web Beacons When you browse certain portions of the Service, we automatically collect and record standard user information and clickstream data about your visit (through the use of cookies and otherwise) as part of our analysis of the use of the Service. For example, when you visit or request a web page from our server, we record the IP address of your machine, the time, date and URL of the request and information about the browser being used, and other information regarding the visit, such as the pages visited on the Service, the time spent on each page, any advertisements clicked and any search terms used (collectively, “Log Data”). Log Data may be aggregated and is used to monitor and analyze use of the Service and to enable us to analyze traffic and trends, administer and improve the Service, identify and keep track of errors and bugs, and gather broad demographic information to become more familiar with where visits to the Service originate, how often the Service is visited and what parts of the Service are visited most often. We also share such information with third party service providers assisting us with the foregoing and with our advertisers. For example, some of this information is collected and used so that when you visit the Service again, it will recognize you and serve advertisements and other information appropriate to your interests. We also use this information to verify that visitors to the Service meet the criteria required to process their requests. We link Log Data to your information for tracking and analyzing our customers’ use of the Service to help improve the Service, to tailor the Service to their needs and to enforce our Terms of Service. A cookie is a small data file that we transfer to your computer’s hard drive. Like many websites, we also use “cookie” technology to collect additional website usage data, to improve the Service and in some cases to enable you to more easily log in to your Account. We may combine information collected through the use of cookies we issue with other information that you provide to us. Super Free Games may use both session cookies and persistent cookies to better understand how you interact with the Service, to monitor aggregate usage by our users and web traffic routing on the Service, and to improve the Service and our other products and services. A session cookie enables certain features of the Service and is deleted from your computer when you disconnect from or leave the Service. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. We may feature advertisements served by third party advertising companies which deliver cookies to your computer or device so the advertisements you see can be tracked. These advertisers may use information about your visits to our Service in order to provide advertisements about goods and services of interest to you. You can instruct your web browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If your browser is set to refuse all cookies, however, some features of the Services may not function properly. We and third party advertising companies may collect information using Web beacons. Web beacons or “gifs”, are electronic images that may be used on our Site, in our Service or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon. Advertisers may use web beacons in connection with our Service in order to collect and use data regarding advertisement performance and your interests for the purpose of delivering relevant advertising to you.
We may use the information we collect, alone or in combination, for various business and commercial purposes, including, but not limited to providing the Service as well as the following:
We may combine any of the information that we collect from you with other information, including information that we obtain from third parties, or with information derived from any other products or services we provide. For example, we may combine personal information you provide us, such as an email address, with information automatically collected about your device. We may use this combined information to, among other things, provide you with personalized recommendations.
We share your information with third parties with whom we have a business relationship such as advertisers, ad networks and analytics providers. The information shared with these third parties may be used for industry analysis, ad targeting, tracking ad conversions or demographic profiling, or other purposes related to providing the Services to you.
We may employ third party companies and individuals to facilitate the Service, to provide the Service on our behalf, or to assist us in analyzing how the Service is used. These third parties have access to your information to perform these tasks on our behalf and we use good faith efforts to obtain their commitment not to use your information for any other purpose.
We may also provide your information to our business partners, group companies or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you.
We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Super Free Games or any third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.
We may transfer your information in connection with a change or transfer of Super Free Game’s ownership, or a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy, including in the course of diligence.
We may share your information with your consent, including where you post information to be shared publicly or with other users. For example, you may post content to a blog, message board, chat room or within Super Free Games’ applications or other forums (“Forums”). Certain of your information, such as your username and other information, will always be publicly visible by other users of the Forums, including when such users view your Account profile page. Your email address will not be publicly visible unless you choose to make it visible in your Account profile page. You may also direct us to share information when you participate in player forums or message boards post comments to other users’ profiles, send private messages or invitations to other users, chat with other users, and post photos in your public Profile.
The sharing scenarios identified above apply to personally identifiable information, not aggregated or anonymous information. We may share aggregated or anonymous information about you and other users with advertisers, publishers, business partners, sponsors, and other third parties, in which case such information may be disclosed and used for a broad range of commercial purposes without limitation.
We may use third-party web analytics services (such as those of Google Analytics and Amplitude) on our Site to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns. The Service may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Service, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. Third parties, whose products or services are accessible or advertised via the Service, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics and others) to serve tailored ads to you on the Service, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Service. We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please note that if you exercise the opt out choices above, you will still see advertising when you use the Service, but it will not be tailored to you based on your online behavior over time.
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your “personal data” (as defined in such applicable laws). To the extent those laws apply, our legal grounds are as follows:
We generally retain information for so long as it may be relevant to the purposes above and in compliance with applicable law. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
Super Free Games takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your Account or any of your information will be protected against, loss, misuse, or alteration by third parties.
When you register for an Account or later access your Account, you will able to adjust settings and preferences within your Account to choose whether to share and make publicly visible other pieces of your information, and the Service will display your information based on the settings and preferences you choose. You can review and revise your Profile information at any time. You may “opt-out” of receiving certain types of communications at any time by contacting our Data Privacy Officer at Super Free Games at dpo@superfree.com. For Residents of the European Union and EEA Countries: Residents of the European Economic Area (“EEA”), can exercise certain data subject rights available to them under applicable data protection laws. Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. If these rights apply to you, they may permit you to request that we:
For more information on how to exercise these rights, please contact us using the information in the “Contacting Us” section below. If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached. For Residents of Nevada: Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by dpo@superfree.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change. For Residents of California: Please click https://superfreegames.com/notice-to-california-residents/ to view details on rights for California residents.
The information discussed in this Privacy Policy is collected and controlled by Super Free Games in the United States. If you are located outside the United States and choose to provide information to us, you agree that such information will be processed in the United States for the purposes described herein. As described above, Super Free Games also may subcontract the processing of your data to, or otherwise share your data with, Super Free Games subsidiaries, service providers, and business partners in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. You expressly consent to such transfer and processing.
The Service may contain links to other websites and online services (“Linked Sites”). The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of their privacy policies or practices. You acknowledge and agree that we are not responsible for the privacy practices of such Linked Sites, and this Privacy Policy does not apply to such Linked Sites. The operators of Linked Sites may collect information about you, and may use and disclose that information. We encourage you to review the privacy policies of the Linked Sites that you use.
The Service is not directed to children under the age of 13. We do not knowingly collect or solicit personally identifiable information from children under 13. If you are under 13, please do not attempt to register for an Account on the Service or send any information about yourself to Super Free Games. If we become aware that a child under 13 has provided us with personal information (as defined by the United States Children’s Online Privacy Protection Act), we will delete such information from our files as required by applicable law. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
If you have any questions about this Privacy Policy, please contact us at dpo@superfree.com.
For Residents of California: This Supplemental Privacy Notice supplements the information in our Privacy Policy, and except as provided herein, applies solely to California residents. It applies to personal information (as defined by the California Consumer Privacy Act) we collect on or through the Service and through other means (such as information collected offline, in person, and over the telephone).
Summary of Information We Collect
California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.
We or our service providers may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):
Examples of these types of uses are identified below. We may also use the below categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
| Categories of Personal Information We Collect | Categories of Sources | Examples of Uses | Categories of Third Parties With Which We May Share That Information |
| Identifiers (such as name, email address) | Your use of our services/automatically collected from you Affiliates Third Parties (such as agents/service providers) | Providing the Service, including to register an account for you Fixing and improving the Service Personalizing content Marketing and advertising Communicating with you, e.g. customer support Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Service, breaches of terms and policies | Third parties (such as service providers) Affiliates |
| Commercial information (such as transaction data) | Your use use of our services/automatically collected from you Affiliates Third Parties (such as agents/service providers) | Providing the Service, including to provide you with virtual currency Fixing and improving the Service Personalizing content Marketing and advertising Communicating with you Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Service, breaches of terms and policies | Third parties (such as service providers) Affiliates |
| Financial data (such as the last four digits of payment cards) | Your use use of our services/automatically collected from you Affiliates Third Parties (such as agents/service providers) | Providing the Service, including to provide you with premium features Fixing and improving the Service Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Service, breaches of terms and policies | Third parties (such as service providers) Affiliates |
| Internet or other network or device activity (such as IP address, unique device, advertising, and app identifiers, browsing history or other usage data) | Your use use of our services/automatically collected from you Affiliates Third Parties (such as agents/service providers) | Providing the Service, including to provide you with virtual currency Fixing and improving the Service Personalizing content Marketing and advertising Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Service, breaches of terms and policies | Third parties (such as service providers) Affiliates |
| Location information (general location, and, if you provide permission, precise geo-location) | Your use use of our services/automatically collected from you Affiliates Third Parties (such as agents/service providers) | Providing the Service Fixing and improving the Service Personalizing content Marketing and advertising Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Service, breaches of terms and policies | Third parties (such as service providers) Affiliates |
| Sensory information (such as audio recordings if you call our customer service) | Your use use of our services/automatically collected from you Affiliates Third Parties (such as agents/service providers) | Providing the Service, including to address your service inquiries Fixing and improving the Service Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Service, breaches of terms and policies | Third parties (such as service providers) Affiliates |
| Inference data about you | Your use use of our services/automatically collected from you Affiliates Third Parties (such as agents/service providers) | Providing the Service, including to recommend games Fixing and improving the Service Personalizing content Marketing and advertising Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Service, breaches of terms and policies | Third parties (such as service providers) Affiliates |
| Other information that identifies or can be reasonably associated with you (such as communications you send us) | Your use use of our services/automatically collected from you Affiliates Third Parties (such as agents/service providers) | Providing the Service, including to address your service inquiries Fixing and improving the Service Personalizing content Marketing and advertising Communicating with you Analyzing use of the Service Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of the Service, breaches of terms and policies | Third parties (such as service providers) Affiliates |
Rights
If you are a California resident, you may have certain rights. California law may permit you to request that we:
You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Service to you. If you ask us to delete it, you may no longer be able to access or use the Service.
If would like to exercise any of these rights, please submit a request at dpo@superfree.com. You will be required to verify your identify before we fulfill your request. To do so, you will need to provide your Super Free Games support ID. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
The CCPA requires businesses that “sell” personal information, as the term “sell” is defined under the CCPA, to provide an opt-out from such sales. While Super Free Games does not believe it “sells” personal information, some people have taken the position that when a website uses third parties’ cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the online service. Some take this position even when the online service pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. If you take the position that use of these sorts of technology involves a “sale” within the meaning of the CCPA, then you may consider Super Free Games to have “sold” what the CCPA calls “identifiers” (like IP addresses), “internet or other electronic network activity information” (like information regarding an individual’s browsing interactions on superfreegames.com), and “commercial information” (like the fact that a browser visited a page directed to people who are considering purchasing from us) to those sorts of companies. To put limits on the collection and/or use of data in these sorts of situations, please use all of the control options described in Section 4 of our Privacy Policy. The CCPA requires that businesses that “share” personal information, as the term “share” is defined under the CPRA, to provide an opt-out from such sharing. If you take the position that the use of the sorts of the technology described above involves a “share” within the meaning of the CCPA, then you may consider Super Free Games to have “shared” what the CCPA calls “personal information”. To put limits on the collection and/or use of data in these sorts of situations, please use all of the control options described in Section 4 of our Privacy Policy. If you take the position that use of these sorts of technology involves a “sale” or “share” within the meaning of the CCPA, then you may “opt-out” by contacting Super Free Games at dpo@superfree.com.
California Shine the Light
Under California’s “Shine the Light” law, California residents who provide personal information (as defined by applicable California law) in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2013 will receive information regarding 2012 sharing activities). To obtain this information please send an email message to dpo@superfree.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
California Do-Not-Track Disclosure
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.
Privacy Policy Addendum – Asia
This section applies to residents connecting from or for the services offered in: South Korea, Hong Kong, New Zealand, Vietnam, Singapore, Thailand, Malaysia, Philippines, Australia.
Consent to the collection, use and transfer of personal information
By using our services, you consent to the collection, transfer and use of your personal information as outlined in this Privacy Policy. This includes consenting to the transfer of your personal information to other parties (including overseas transfers) as outlined above in sections 4, 10 and 11 of this Policy.
You may withdraw your consent at any time. Withdrawing your consent may impact your ability to use our Services, as the use of your personal information is necessary for the functioning of the Services.
Retention and methods of destruction of personal information
When personal information becomes unnecessary, the retention period has expired or the purpose of processing has been achieved, we take appropriate measures to render the personal information unreadable and/or unidentifiable. This may include permanent deletion of your personal information that we have collected. Please see section 6 of this Privacy Policy for more information about retention periods.
If we must keep your personal information in order to comply with relevant laws or regulations, your information will be stored separately and only used for such compliance purposes.
We remove and destroy personal information in accordance with applicable law and only for the duration of the relevant retention period (as set out in this Privacy Policy). Personal information stored in electronic form is destroyed and/or anonymized so that it cannot be reasonably reproduced and physical records are destroyed by actions such as shredding or incineration.