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PRIVACY POLICY

Last updated January 14, 2014

OUR COMMITMENT TO PRIVACY

SomaSim, LLC (“we” or “SomaSim”) is committed to maintaining the security, confidentiality and privacy of your personal information. This is our Privacy Policy. This document states our commitment to your privacy in compliance with the California Online Privacy Protection Act of 2003.

SCOPE OF POLICY

We own and operate the somasim.com website and various computer games. This Policy applies to our collection, use and disclosure of your personal information in connection with our operation of our website and games. This Policy does not impose any limits on our collection, use or disclosure of the following information:

  • business contact information; and
  • certain publicly available information.

PURPOSES

When collecting personal information, we will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection.

We collect, use and disclose your personal information for the following purposes:

  1. to provide and administer requested products and services, and to disclose the information for any purpose related to operation of accounts and provision of requested products and services;
  2. to communicate with you through our website and email;
  3. to authenticate your identity;
  4. to monitor your compliance with any of your agreements with us;
  5. to provide personal information to third party suppliers of products and services;
  6. to manage or transfer our assets or liabilities, for example in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products;
  7. to protect us, yourself and others from fraud and error and to safeguard our business interests;
  8. to collect debts owed to us;
  9. to comply with legal and regulatory requirements; and
  10. to distribute to third parties including financial institutions, payment processors, lawyers, financial institutions and government licensing bodies for any of the above purposes.

The above collections, uses and disclosures are a reasonably necessary part of your relationship with us.

CONSENT

We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where:

  • the information is publicly available, as defined by statute or regulation;
  • we are obtaining legal advice; or
  • we reasonably expect that obtaining consent would compromise an investigation or proceeding.

Other exceptions may apply.

Your consent can be express, implied or given through an authorized representative. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.

You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice. When we receive notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.

LIMITS ON COLLECTION OF PERSONAL INFORMATION

We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.

LIMITS FOR USING, DISCLOSING AND RETAINING PERSONAL INFORMATION

Your personal information will only be used or disclosed for the purposes set out above and as authorized by law.

We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.

We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose.

We will take due care when destroying personal information so as to prevent unauthorized access to the information.

OTHER INFORMATION

We may collect non-personally identifying information of the sort that web browsers, games and servers typically make available, such as the browser or platform type, language preference, referring site, and the date and time of each visitor request or game session. We collect this non-personally identifying information to better understand how our visitors and players use our site and our games. We may release aggregate non-personally identifying information from time to time, e.g., by publishing reports on trends in the usage of our site or games.

We also collect potentially personally-identifying information like Internet Protocol (IP) addresses for visitors that log into our site or a game. We only use and disclose logged-in user IP addresses under the same circumstances that we use and disclose personal information as described in this Privacy Policy.

E-MAIL COMMUNICATION

If you are registered user of our site or one of our games or signed up for our newsletter and have supplied your e-mail address, we may occasionally send you e-mails to tell you about new games, features or other products or services, or to solicit your feedback. If you send us a request (e.g., through a support e-mail or one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.

COOKIES

SomaSim may use cookies to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can be read only by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page, so that when you visit the site again, the experience will be personalized. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Websites or the other Websites you visit.

SomaSim uses analytics services, including but not limited to Google Analytics, an analytics service provided by Google Inc. (“Google”), and Mixpanel. Google Analytics and Mixpanel use cookies to help analyze how visitors arrive at and use the Site, and provide us with statistical reports on Services activity. The information generated by the cookies or other technologies about your use of the Services (including IP address) (the “Analytics Services Information”) is transmitted to Google Analytics or Mixpanel and potentially stored on servers in the United States. Google Analytics and Mixpanel will use the Analytics Services Information to compile reports on the activity on the Services for us. The Analytics Services Information will also provide us with other services related to activity on the services provided by SomaSim and internet usage. Google and Mixpanel may also transfer the Analytics Services Information to third parties where required to do so by law, or where such third parties process the Analytics Services Information on their behalf. Google’s use of the Analytics Services Information is governed by the Google Terms of Service and the Google Privacy Policy; Mixpanel’s use of the Analytics Services Information is governed by the Mixpanel Terms of Use and the Mixpanel Privacy Policy. You may refuse the use of cookies by selecting the appropriate settings on your browser. By using services provided by SomaSim you consent to the processing of data about you by Google and / or Mixpanel in the manner and for the purposes set out above.

COMMUNITIES AND FORUMS

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Communities, Forums, Messages, or other public online forums, this information may be collected and used by others. We recommend that you be cautious in giving out personal information to others in these public online forums.

CHANGES TO THIS STATEMNT

This Privacy Statement applies only to websites and services directly provided by SomaSim and not other companies or organizations to which we may provide links from this website or services not provided directly by SomaSim. SomaSim will occasionally update this Privacy Statement. When we do, we will also revise the “last updated” date at the top of the privacy statement. For material changes to this Statement, SomaSim will notify you by placing prominent notice on the Website. We encourage you to periodically review this Privacy Statement to be informed of how we are protecting your information.

ACCURACY

We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.

CONTACT INFORMATION

SomaSim welcomes your comments regarding this Privacy Statement. If at any time you believe that our websites or services have not adhered to this Privacy Statement, please notify us and we will use all commercially reasonable efforts to promptly determine and correct the problem.

If you have questions regarding this statement or require additional information, please contact us.