- Privacy by design principles
- Personal information we collect
- How we user your information
- Disclosing your information to third parties
- International data transers
- Your choices
- Your privacy rights
- Data retention
- Security of your information
- Third party websites/applications
- Children’s information
- Surpervisory authority
- Contact us
Effective Date: May 1, 2020
Solsten, Inc. (“Solsten,” “we,” “us,” and “our”) wants gaming and online experiences to be awesome, just like you. You can help us. We
provide a user experience service to website, app, and game developers and publishers (each a “Developer and/or Publisher”) to help them learn about and understand what players or users like you really want from a website, app, or game. In some cases, you may also complete certain Assessments so that we can give you suggestions for video games and other online experiences you may enjoy.
By completing our Assessment, we hope to learn more about you and other users who use the same services as you so that we can make suggestions and recommendations to our clients (i.e., Developers and/or Publishers) as to how they can build more engaging experiences for their users (including you) (e.g., via design or new features) and how they can approach and interact with their users (including you) (e.g., via marketing or targeting). In some cases, we can give you suggestions for video games and other online experiences you may enjoy.
PRIVACY BY DESIGN PRINCIPLES
Your privacy is important to us. We appreciate that you trust us with your data and want to share some of the privacy-by-design features we’ve incorporated into our Assessments with you:
- You Control Your Data. You choose whether or not to provide us with responses to
- Solsten Doesn’t Know Who You Are. Our Assessments are linked to pseudonymous
identifiers and we are not able to identify you in the real world unless you
instruct us to. It’s possible that a Developer and/or Publisher may know who you
are, but they do not share this information with us.
- Assessment Responses Are Not Shared. Your raw responses to Assessment questions
are never shared with the Developer and/or Publisher that we are working with.
PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with our Services.
Information You Provide to Us
Assessments. When you provide responses to an Assessment, we do not ask for any personal information that can identify you in the real world (e.g., name, email address, etc.). However, the Assessment may ask you to provide information such as your gender, age, education level, and the country where you live. Assessments may also ask you for other information such as your values and behaviors, your likes and dislikes, preferences, daily activities and other relevant questions.
In addition, if we are working with a Developer and/or Publisher and you choose to provide responses to an Assessment, the related Developer and/or Publisher will automatically provide Solsten with the Developer and/or Publisher’s internal, pseudonymous identifier that it has associated with you (“Developer and/or Publisher ID”). The Developer and/or Publisher may also provide Solsten with additional information as detailed below in the “Information from Other Sources” section.
For some Assessments, you may be able to request that Solsten provide you with a randomized alphanumeric identifier (“Solsten ID”). If you choose to request a Solsten ID, Solsten will use this to retrieve your Assessment information should you
choose to contact us in the future.
Your Communications with Us. We collect personal information from you such as your email address when you sign up to receive email updates, request information about our Services, or otherwise communicate with us.
Surveys. In addition to our Assessments, we may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features. We may offer interactive features such as blogs and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive
features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.
Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Solsten and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Information Collected Automatically
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, cookie or other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, and information about how you interact with and use the Services.
Information from Other Sources
Developers and/or Publishers. In some cases, we work with Developers and/or Publishers when we carry out Assessments. As part of this process, Developers and/or Publishers may provide us with additional personal information that they have collected about you which is keyed to the Developer and/or Publisher ID. This information may include, but is not limited to, related gameplay data and monetization data. In some cases, our agreement with the Developers and/or Publishers may limit our use of this data, but we will
HOW WE USE YOUR INFORMATION
We use your personal information for a variety of purposes,
To Provide the Services or Information Requested, such as:
- Fulfilling our contract with you (e.g., the Terms of Service);
- Helping Developers and/or Publishers improve their services;
- Helping Developers and/or Publishers tailor and provide advertisements to you
- Providing you with suggestions for video games and other online experiences
you may enjoy;
- Responding to questions, comments, and other requests;
- Providing access to certain areas, functionalities, and features of our
- Answering requests for customer or technical support.
Administrative Purposes, such as:
- Pursuing legitimate interests, such as direct marketing, research and
development (including marketing research), network and information security,
and fraud prevention;
- Measuring interest and engagement in our Services;
- Improving the Services;
- Developing new products and services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Carrying out audits;
- Communicating with you about your account, activities on our Services and
- Preventing and prosecuting potentially prohibited or illegal activities;
- Enforcing our agreements; and
- Complying with our legal obligations.
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES
We may share your personal information with the following
categories of third parties:
Developers and/or Publishers. When you provide responses to an Assessment that we are carrying out pursuant to a partnership we have with a Developer and/or Publisher, you acknowledge and agree that you are using our Services to interact with the related Developer and/or Publisher and that we may share your information with them. We do not share you Assessment responses with the Developer and/or Publisher, but we may share your psychological profile traits and attributes that we develop or derive from your Assessment responses. In addition, the Developer and/or Publisher may be able to link the information we provide them with to personal information that can be used to identify you in the real world (e.g., your name and
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) customer service activities; and (v) the provision of IT and related services.
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers fDisclosures to Protect Us or Others. We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
INTERNATIONAL DATA TRANSFERS
We may share your personal information with the following categories of third parties:
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
General. You may have the right to opt out of certain uses of your personal information.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.
Please note you must separately opt out in each browser and on each device.
YOUR PRIVACY RIGHTS
For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or
restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that if you completed an Assessment, Solsten will not be able to
authenticate your identity unless you provide us with your Solsten ID.
If you are a California resident, you have the right not to receive discriminatory treatment by Solsten for the exercise of your rights conferred by the California Consumer Privacy Act.
SECURITY OF YOUR INFORMATION
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services.
THIRD PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
516 N Sepulveda Blvd
Manhattan Beach, CA 90266
Schönhauser Allee 43a
Solsten S.à r.l
21, rue Giesener