Privacy Policy

Who this Policy applies to: By using the App or visiting the Website you are agreeing to be bound by this Policy in respect of the information collected about you. Traceberry DMCC may change this Policy at any time. Traceberry DMCC shall deem your continued use of the App or access of the Website as indicating your consent to such changes. This Policy applies to the following people:
• visitors to the Website;
• people who use the App
• people who make complaints to us by email; and
• job applicants and Traceberry’s current and former employees.
Who We are
We are Traceberry DMCC, a real-world augmented reality platform designed to enable you to interact in a seamlessly blended real world. To provide you with this user experience, we need information about you. Protecting your privacy is our top priority. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you play our game, use our websites, buy merchandise through us, or take part in live events and promotions (the "Services"). The Website is essentially a brochure for Traceberry’s business, its App and opportunities to work with and for Traceberry DMCC.
You should also read our Terms & Conditions which set out the contract between you and Traceberry DMCC.
1. Who decides how your information is used?
Traceberry DMCC, is the data controller responsible for making decisions about how we use your personal information. If you have any questions or comments on this policy, you can:
• Email us at info@traceberry.com
• Write to us at info@traceberry.com
• Contact our Privacy Department at info@traceberry.com
2. The information we collect about you and how we use it
This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").
We need to collect and use certain Personal Data to provide the Services to you and fulfil the promises we make to you in the Terms of Service: • When you sign up for our Services you give us Personal Data voluntarily by providing it to us, for example when you sign up for an account. We collect and use that information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services. That information includes the in-app username you choose to use on our Services.
• You must have an account with a supported third party single sign-on service to use our Services. As such, the Personal Data we collect also depends on which third party accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access Traceberry DMCC Services.
o If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address.
Some third-party providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.
• We collect and use your device location information as you use our Services, including how you move around and events that occur during app usage. Our Services include location based apps, so we need to know where you are to operate these apps for you, and to plan the location of in-app resources (for example which offer is nearest to you and which zone you are in). We identify your location using a variety of technologies, including GPS, Bluetooth, the WiFi points you are accessing the Service through and mobile/cell tower triangulation.
• We also collect and use your in-app actions and achievements as well as certain information about your mobile device collected during app-play (including device identifiers, device OS, model, settings and information about third party applications installed on your device), to operate the Services for you and to ensure that we provide a fair experience to all users in accordance with our Terms of Service.
• We also use the information above to show in-app locations that are in your vicinity as part of the app-play experience.
• We further use the information above in order to provide technical and customer support to you.
• You also give us Personal Data when you make a purchase through us or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, date of birth (as needed to verify eligibility), and email address. We use that information to fulfil those Services to you and to provide related customer support to you.
In addition, we have and rely on a legitimate interest in using your Personal Data as follows:
• Using your IP address, browser type, operating system, the web page you were visiting before accessing our Services, the pages of our Services which you browsed or the features you used, and the time spent on those pages or features, the links on our Services that you click on, device identifiers, as well as actions you take during gameplay, your in-game user settings and preferences and your purchases through our app to understand who is using our Services and how.
• Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.
• Using your email address and device information in order to share updates and news about the Services with you either within the app or by email.
• To offer new or additional features for our Services.
• To complete your transaction.
• To facilitate the improvement of the App and your experience of the App.
• To provide technical support in relation to user enquires, resolving disputes and troubleshooting.
• To make legal or regulatory disclosures.
We will only use your Personal Data to do the following if we have your consent:
• Send you marketing materials by email.
While you may disable the usage of cookies through your browser settings, Traceberry DMCC currently does not respond to a "Do Not Track" signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.
3. Who we share information with
We will not share any Personal Data that we have collected from or regarding you except as described below:
Information Shared with Our Services Providers. We engage third party service providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These third party service providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The service providers we use help us to:
• run, operate and maintain our mobile games through third party platform and software tools;
• perform content moderation and crash analytics;
• run email and mobile messaging campaigns;
• perform game and marketing analytics;
• provide technical and customer support.
Information Shared with Other Users. When you use the Services, and in particular when you use our app or take part in live events, we may share certain Personal Data with other players. This Personal Data includes your in-game username, your avatar, your in-game actions and achievements, and your public in-game messages. For some games, this might include your location.
Information Shared with Third Parties. We share Anonymous Data with third parties for industry and market analysis. We do not share Personal Data with any other third parties for their direct marketing purposes.
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 only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (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 investigate and stop any activity that we consider illegal, unethical, or legally actionable.
Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including Personal Data, is a business asset. 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 Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.
4. How your Personal Data is transferred
Traceberry DMCC operates its Services across the globe. Your Personal Data will very likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy. The data protection laws in these countries may not be the same as in your home country.
If we transfer your Personal Data from the European Economic Area (EEA) to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the EEA by ensuring that at least one of the following safeguards is implemented: • The country that your Personal Data is transferred to is a country that the European Commission has deemed to provide an adequate level of protection for Personal Data as the EEA.
• We use specific contracts approved by the European Commission which give Personal Data the same protection as it has in Europe when we engage with service providers.
• Where we engage with service providers in the USA, they are part of the EU-US Privacy Shield, which requires them to provide the same protection of your Personal Data as it has in the EEA.
5. How we keep your Personal Data safe
We have appropriate security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. How long we will keep your Personal Data
We keep your Personal Data for as long as we need to provide the Services to you and fulfil the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.
When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you.
7. Your rights and choices
You have certain rights in relation to your Personal Data. In order to exercise these rights, please contact us at:
• Traceberry Go Here http://traceberry.net/#contact-page
If you're a user based in the EEA (or in any country that mandates similar rights), you can:
• Request access to the Personal Data we hold on you.
• Delete or correct your Personal Data. The easiest way to update your account information is via your in-app settings. You can also submit a customer support request through our support website http://traceberry.net/#contact-page) for Traceberry.
• Object to us processing your Personal Data. Some of the Personal Data we hold is necessary for us to provide the Services to you and fulfill the promises we make to you in the Terms of Service.
• Ask us to stop using your Personal Data, including for marketing and promotional purposes (but be aware that sometimes we need to use your Personal Data in order for you to use the Services).
• Have your Personal Data transferred to another organization (where it is technically feasible).
• Complain to a regulator. We'd appreciate the chance to deal with your concerns directly so we'd prefer you to contact us first.
The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.
We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.
We aim to provide the information or complete the outcome you request within 30 days.
8. Changes to this Privacy Policy
Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.
9. Third Parties In using our Services you may access links to websites and services that are owned or operated by third parties (each, a "Third Party Service"). Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third Party Service that you access.

Updated on November 2018