GAME COMMERCE

Privacy Policy

Last updated: September 12, 2018

This is the privacy policy (“Privacy Policy”) that governs how Game Commerce, Inc. (“Game Commerce”, “we”, “our” or “us”), use Personal Data (defined below) that we collect, receive and store about you in connection with your use of our website: www.gamecommerce.com (the “Site”) and our mobile interactive advertising services, mobile advertisements, and related services we operate (together with the Site, the “Services”). 

You may choose whether or not to provide or disclose Personal Data in connection with your use of the Services. If you choose not to provide the Personal Data we request, you may still visit and use parts of the Site and/or the Services, but may be unable to access or use certain features, options, programs, and services. The Services may contain links to third-party websites and services that are not owned or controlled by Game Commerce. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk.

1. Introduction.

We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using the Services. As used in this Privacy Policy, “Personal Data” means any information that may be used, either alone or in combination with other information, to personally identify an individual.

2. Changes to this Privacy Policy. 

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE. 

3. Personal Data Collected.

3.1. Personal Data You Provide To Us On The Site. 

a) Types of Personal Data. We and our service providers collect the Personal Data set forth below in order to provide the Site to you, or because we are legally required to do so. If you do not provide the Personal Data we request, we may not be able to provide you with the Site. The Personal Data we and our service providers collect includes but is not limited to:

  • Your name;
  • Email address;
  • Username;
  • Password; 
  • Information included in your resume; and
  • Communications you send to us.

b) When Personal Data is Collected. You may be required to provide us with certain information that may constitute Personal Data in the following ways: 

  • Contact Information

In various areas of our Site, we provide you the opportunity to submit a form with basic contact information, such as your name and email address. With your permission, Game Commerce uses such information to inform you of new products and services, and upcoming events that may be of interest. If you no longer wish to receive these emails, the opt-out process is described in Section 7.2 of this Privacy Policy.

  • Login Information

We process your email username and password to enable you to securely log into the Customer-restricted area of the Site, and we process that information to appropriately control access to restricted content. We process this Personal Data only as necessary to provide you the Services on the Site and to further our legitimate interests in protecting the Services, the Site, and our content.

  • Information Collected through Various Forms 

We and our service providers may collect Personal Data in a variety of ways, including: (i) through use of our Site, e.g., when you sign up for a newsletter; (ii) offline, such as through in-person referrals and through sign-in information at our front desk; or (iii) from other sources, such as public databases, joint marketing partners, and from other third parties.

3.2. Personal Data You Provide To Third Parties In and Through The Services. Please note that we use certain third party service providers as part of the Services to enhance your experience or deliver certain services. These providers may collect Personal Data about you in performing their services and/or functions related to the Services. For more information on our third party service providers, and their privacy practices, please click here.

3.3. Information Collected Automatically. Certain information is collected automatically in the Services by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of the Services. Alone or in combination with other information, such automatically collected information may constitute Personal Data. Some of our service providers (described in Section 5, below) may use cookies or other methods to gather information regarding your use of the Services. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of the Services with any Personal Data about you that they may have. The use of such information by a third party depends on the privacy policy of that third party. 

a) Log Files On The Site. The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (“ISP”), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. 

b) Cookies. We use cookies to make interactions with the Site easy and meaningful. When you visit the Site, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to us, such as by filling out a web form, you remain anonymous to us.

We may use cookies that are session-based and persistent. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate the Site, but you may not be able to successfully use all of the features of the Site.

The following sets out how we may use different categories of cookies and your options for managing cookie settings:

Type of Cookies Description Managing Settings
Required cookies Required cookies enable you to navigate the Site and use its features, such as accessing secure areas of the Site and using our services.
If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into our Site, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into the Site and to process your online transactions and requests.
Because required cookies are essential to operate the Site, there is no option to opt out of these cookies.
Performance cookies These cookies collect information about how you use our Site, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Site functions and performs.
From time-to-time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Site. We may also utilize Flash cookies for these purposes.
To learn how to opt out of performance cookies using your browser settings click here.
To learn how to manage privacy and storage settings for Flash cookies click here.
Functionality cookies Functionality cookies allow our Site to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Site to personalize your visit.
To learn how to opt out of functionality cookies using your browser settings click here.
To learn how to manage privacy and storage settings for Flash cookies click here.
Targeting or Advertising cookies From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Site. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Site. The information provided to third parties does not include Personal Data, but this information may be re-associated with Personal Data after we receive it.
By way of example, as you browse the Site, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Site.
Third parties, with whom we partner to provide certain features on the Site or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.
To learn more about these and other advertising networks and their opt out instructions, click here.
To learn how to manage privacy and storage settings for Flash cookies click here.

c) Other Tracking Technologies. When you visit the Site, we may collect your IP address for certain purposes such as, for example, to monitor the regions from which you navigate the Site. We may also use web beacons alone or in conjunction with cookies to compile information about your usage of the Site and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to the Site. We may use web beacons to operate and improve the Site and email communications.

d) Analytics Software Tools. We use Google Analytics on the Site to help us analyze the traffic on the Site. For more information on Google Analytics’ processing of Personal Data, please see http://www.google.com/policies/privacy/partners/. By using a browser plugin http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics. 

4. The Purposes For Which We Use Personal Data.

If you submit or we collect Personal Data through the Services, then such Personal Data may be used in the following ways: (i) to provide, analyze, administer, and improve the Services; (ii) to contact you in connection with the Services and notifications, events, programs or offerings that you may have registered for; (iii) to send you updates and promotional materials that you have registered for; (iv) for recruiting and other  human resources-related purposes; (v) to identify and authenticate your access to the parts of the Site and the Services that you are authorized to access; and (vi) to protect the rights and/or our property and to ensure the technical functionality and security of the Services.

5. How We Disclose Personal Data.

We do not sell, lease, rent or otherwise disclose the Personal Data collected through the Services to third parties unless otherwise stated below or with your consent.

5.1. Our Third Party Providers. We transfer Personal Data to our third party service providers that perform tasks on our behalf, and that assist us in providing the Services, as more fully described in Section 3.2. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Data. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers as well as any transfer restriction that is specified in an agreement between Game Commerce and a customer.

5.2. In the Event of Merger, Sale, or Change of Control. We may transfer or assign this Privacy Policy and any Personal Data to a third party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control.

5.3. Other Disclosures. We may disclose Personal Data about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Game Commerce, our users, or the public.

6. Retention of Personal Data.

We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 4 (The Purposes For Which We Use Personal Data), and (ii) comply with applicable law.

7. Your Rights.

7.1 Personal Data. If you have an account on the Site, to the extent we are legally required, we provide access to—and the ability to edit or delete—certain categories of Personal Data through the account. 

If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via the Site, you may submit a request to privacy@gamecommerce.com or write to us at: 

Game Commerce, Inc.

440 North Wolfe Rd.

Sunnyvale CA, 94085

We will promptly review all such requests in accordance with applicable laws. 

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you. We encourage you to first reach out to us at privacy@gamecommerce.com so we have an opportunity to address your concerns directly before you do so.

7.2. Opting-Out of Promotional Emails. You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us, or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences to privacy@gamecommerce.com.  Customers cannot opt out of receiving transactional emails related to their account with us or our services. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).

8. Personal Data Transferred from the EU or Switzerland To The United States.

Game Commerce complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data from European Union (the “EU”) member countries and Switzerland. Game Commerce has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity, Purpose Limitation, Access, Recourse, Enforcement, and Liability. A violation of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, to the extent available, please visit https://www.privacyshield.gov.

In compliance with the Privacy Shield Principles, Game Commerce commits to resolve complaints about your privacy and our collection or use of Personal Data about you. Persons from the EU or Switzerland who have inquiries or complaints regarding this Privacy Policy should first contact us via email at: privacy@gamecommerce.com.  

Game Commerce has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.

These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the Privacy Shield, Game Commerce is potentially liable.

9. Data Security.

The security of Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.

10. Children’s Privacy.

The Site or the Services are not intended for children under the age of 13. Accordingly, we do not intend to collect Personal Data from anyone we know to be under 13 years of age.

11. How We Respond to Do Not Track Signals.

Game Commerce does not track Site users over time and across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about an individual consumer’s online activities over time and across third-party websites or online services.

12. Your California Privacy Rights. 

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Data about you by Game Commerce to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to privacy@gamecommerce.com or write to us:

Game Commerce, Inc.

440 North Wolfe Rd.

Sunnyvale CA, 94085

13. Contacting Us.

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to privacy@gamecommerce.com. 

Appendix 1

(NOTE TO WEB DEVELOPER: Post this as a separate page on the website. Do not post as part of privacy policy)

Third Party Service Providers For the Site

Omniture (Adobe) for analytics. For information on this service provider’s privacy practices, please visit https://www.adobe.com/privacy.html. 

Facebook Pixel for advertising analytics. For information on this service provider’s privacy practices, please visit https://www.facebook.com/about/privacy. 

Appendix 2 

(NOTE TO WEB DEVELOPER: Post this as a separate page on the website. Do not post as part of privacy policy)

Cookie Banner:

This site uses technologies such as cookies to personalize content and ads, analyzing web traffic and trends, and improve site operations. We may share information about your use of the site with third parties in accordance with our Privacy Policy. You can change your Cookie Settings at any time, but parts of our site may not function correctly without them.

[I Accept]

Appendix 3

(NOTE TO WEB DEVELOPER: Post this as a separate page on the website. Do not post as part of privacy policy)

Cookie Settings

A cookie is a small amount of data that stores information about a user on web browsers or mobile devices. 

How do I turn cookies off?

It is usually possible to stop your browser from accepting cookies, or to stop it accepting cookies from a particular site. However, if your device does not have cookies enabled, your experience on our site may be limited, thereby impeding the navigation and use of our services. 

All modern browsers allow you to change your cookie settings. You can usually find these settings in the Options or Preferences menu of your browser. To understand these settings, the following links may be helpful, or you can use the Help option in your browser for more details.

Cookie settings in Internet Explorer
Cookie settings in Firefox
Cookie settings in Chrome
Cookie settings in Safari web and iOS.

If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to the Your Online Choices site or by visiting the Network Advertising Initiative’s Opt-out page, where you can control third-party online advertising. Please note that there are many more networks listed on this site than those that we use on our site.

Useful links:

If you would like to find out more about cookies and their use on the Internet, you may find the following links useful:

Microsoft Cookies guide
All About Cookies

For further legal information about privacy issues, you may find these links useful:

General Data Protection Regulation (GDPR)
GDPR FAQs 

If you would like to contact us about cookies please email us at hello@gamecommerce.com. Please review our Privacy Policy for more information on our use of cookies and other software tools.