Privacy Policy

DENALI PUBLISHING LLC PRIVACY POLICY

Last Revised: December 9, 2019

Welcome to Denali Publishing LLC.  Your privacy is important to us.

Denali Publishing LLC and its affiliates (“Denali”, “us”, “our” or “we”) are dedicated to protecting the privacy rights of our users (“users” or “you”).  This Privacy Policy (the “Policy”) describes the ways we collect, store, use, and share the information, including personal information, that you provide or we collect in connection with our websites, including www.denalipublishing.com, www.spiesindisguisegame.com,  (the “Sites”) or any Denali game provided on a mobile platform (for example, iOS and Android) (collectively, the “Service”).

If you are located in the European Union (“EU”), this Privacy Policy also informs you about the management of your personal data and your rights in accordance with Article 13 of the General Data Protection Regulation (“GDPR”).

This Policy applies to information collected by Denali and any affiliated or subsidiary entities, including, but not limited to all websites and apps that post a link to this Policy. If you do not agree to these terms, please do not use the Sites or Service.

Data Controller

Denali is the entity responsible for determining the means and purposes of processing personal information (i.e., the data controller) under this Policy and can be contacted as explained below in the How to Contact Us section.

Changes to this Policy

We ask that you read this Policy from time to time. We may modify it at any time in our sole discretion. If we make material changes to this Policy that increase our rights to use personal information that we have previously collected about you, we will obtain your consent, where required by law, either through your registered email address or by prominent posting on the Sites or Service. If Denali intends to further process personal information for a purpose other than that for which the personal information was collected, prior to that further processing, Denali shall provide you with information on that other purpose and with additional information necessary to ensure fair and transparent processing. If you are an individual who is located outside of the EU, your use of the Sites and Service indicate that you accept the terms of this Policy.

If you have questions or concerns about this Policy or our practices, please contact us at info@denalistudios.com.

Personal Information We Collect

Denali may collect personal information about you when you register to use the Service, log in with social networking credentials, interact with the Sites and Service, submit information through the Sites or Service, or otherwise communicate with us. Such information includes, but is not limited to, your name, email address, postal address, username and password for registration, profile photo, age or birthday, user name(s), and social network information.

Forums and Private Messages

Our Sites and Service may offer publicly accessible blogs, private messages, message boards and community forums. Any information that you provide through these services may be read, collected and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at info@denalistudios.com. If you use Facebook Connect to access our blog or community forums, the information you provide will be tied to your Facebook account. You will need to contact Facebook directly in order to request removal of personal information from our blog or community forum.

Invite a Friend

Denali may offer you the opportunity to invite contacts from your social networking service (such as your Facebook friends) to join you in Denali games. Such contact information will be used only for the purpose of sending communications to your contacts. You or your contacts may contact us at info@denalistudios.com to request removal of this information from our database to the extent that Denali stores this information.

Customer Service

We may collect your email address and any other information you provide to us when you contact customer service.

Surveys, Sweepstakes and Contests

We collect any information that you provide if you respond to surveys that we may conduct about our Service. In addition, if you participate in a sweepstakes or contest that we may offer through our Service, we will collect certain information from you. Participation is voluntary, and you therefore can choose whether or not to provide information to us. The requested information typically includes contact information (such as name and shipping address) and demographic information (such as zip code).

Social Media Services

You can log in to our Sites and Service using social media services, such as Facebook Connect, Google Play Game Services, Apple’s Game Center, or an Open ID provider. These services will authenticate your identity and provide the option to share with Denali certain personal information, such as your name, email address, and resumé to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on the Sites to your profile page and to share with others within your network.

Personal Information We Automatically Collect

In addition, we automatically collect information about the devices that you use to interact with our Sites and Service. The information that we automatically collect may include your IP address, operating system, browser type, hardware type, referring website address, device identifier (including media access control (“MAC”) address and international mobile equipment identifier (“IMEI”), device name, location (based on IP address), page and app viewing information, date and time you viewed pages or apps, and language.

Location Information

We may collect information about your location for the purpose of providing you with the correct version of the application. We also may, with your permission, collect your precise geolocation information so that we can match you with other players in your area. We will not share this information with any third party without your permission, unless we are legally obligated to do so. If you no longer wish to allow us to collect or use this information, you may configure your device to prevent collection of location information. Please note that the application may not work properly if we are unable to determine the country in which you are located.

Social Media Features and Widgets

Our Sites include social media features (“Features”), such as Facebook Like buttons, and widgets (“Widgets”), such as Share buttons and other mini-programs that run on our Sites. These Features may collect your IP address, which page you are visiting on our Sites, and may set cookies to enable the Features to function properly. Features and Widgets are either hosted by a third party or hosted directly on our Sites. Your interactions with them are governed by the privacy policies of the companies providing them.

Social Media Services

When you log in through social media services, we may automatically collect information through them in accordance with their policies and terms of service. The information we collect may include your name; your social media service user ID or user name; locale, city, state and country; gender; birthdate; email address; profile picture or its URL; and the social media service user ID numbers for your friends who are also connected to Denali’s games. Please refer to the privacy settings of the social media service for information about what data is shared with Denali and other connected applications and to manage information that is shared through your account. If you want to delete the data that we receive from social media services, please contact us at support@denaligames.com.

Game Data

Whenever you play our games, we collect data about your interaction with the Service and with other players inside the game. This information may be associated with your player ID, IP address or device ID.

You may use some aspects of the Sites and Service without providing any personal information. While providing personal information is voluntary, you may not be able to take advantage of or participate in parts of the Service, if you choose not to share it.

How We Use Personal Information We Collect

We use your personal information for the following purposes:

  • To create game accounts and allow users to play our games;
  • To operate and improve our games;
  • To identify and suggest connections with other Denali users;
  • To enable you to communicate with other users;
  • To provide customer support;
  • To track your use of the games;
  • To communicate with you regarding updates, rewards, promotions, sweepstakes, contests, surveys and other opportunities and news offered by Denali and our selected partners;
  • To contact you about your experience using the games;
  • To notify you of prizes you have won and to send you merchandise or other physical promotional materials;
  • To understand your preferences and personalize your experience while using the games;
  • For internal operations, including troubleshooting, data analysis, testing, analyzing user trends, research and statistical purposes;
  • To connect social media to the Service and Sites;
  • To deliver relevant advertising to you;
  • To protect against and detect fraud, abuse or other unlawful activity;
  • To send you confirmations, invoices, technical notices, security alerts, and support and administrative messages;
  • To enforce our Terms of Service, other corporate policies and industry standards; and
  • To comply with all applicable laws and reporting obligations.

Unsubscribing from Communications

Denali would like to use your personal information to communicate with you directly, via email, about products and services that we believe may be of interest to you, as well as for customer support. If you no longer want to be contacted, you may update your email preferences by using the “Unsubscribe” link found in the email we send to you or by contacting us at info@denalistudios.com.

Push Notifications

We may occasionally send you push notifications through our mobile applications to send you game updates, high scores and other service related notifications that may be of importance to you.  To disable push notifications, access Settings on your device and select the apps from which you no longer want to receive push notifications.

Do Not Track

We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.

How We Share Your Personal Information

Denali will share your information only has described below or with your permission:

  1. With Your Consent

We will share your information with other third parties for their own advertising and marketing purposes, subject to their own privacy policies. If you no longer wish to allow us to share your information with such third parties, please contact us at info@denalistudios.com. If you no longer wish to receive information from third parties, please contact the third party directly.

  1. To Support Business Services and for Advertisements

We may engage other companies and individuals to perform services on our behalf. For instance, we may engage third parties to analyze data, provide customer support, conduct surveys and sweepstakes, and process any purchases you make. These service providers may have access to your personal information in connection with preforming these services on our behalf, but they do not have independent rights to use the information.

  1. Merger, Sale or Other Asset Transfer

We may share your personal information in connection with a merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notice on our Sites of any change in ownership.

  1. Aggregated and Anonymized Information

We may share aggregated or anonymized information about you with advertisers, publishers, business partners, sponsors, and other third parties.

We also may disclose information about you:

  • If we are required to do so by law or legal process;
  • To law enforcement authorities or other government officials pursuant to lawful requests;
  • To verify compliance with and enforce our Terms of Service and other policies governing our Sites and Service;
  • To protect our property, Service and legal rights;
  • To protect personal safety or the property of others;
  • To support auditing, compliance and corporate governance functions; or
  • To comply with any and all applicable laws.

Cookies and Other Tracking Technologies

We and our marketing and outsourcing partners, affiliates, or analytics service providers use technologies such as cookies, beacons, scripts, and tags to identify a user’s computer/device and to “remember” things about your visit, such as your preferences or a user name and password.  Information contained in a cookie may be linked to your personal information, such as your user ID, for purposes such as improving the quality of our Service, tailoring recommendations to your interests, and making the Service easier to use.  You can disable cookies at any time, although you may not be able to access or use features of the Service.

We may feature advertisements served by third parties that deliver cookies to your computer/device so that the content you access and advertisements you see can be tracked.  Because the third-party advertising companies associate your computer/device with a number, they will be able to recognize your computer/device each time they send you an advertisement.  These advertisers may use information about your visits to our Service and third-party sites and applications in order to measure advertisement performance and to provide advertisements about goods and services of interest to you. This Policy does not apply to, and we are not responsible for the data collection practices of these third-party advertisers, and we encourage you to check their privacy policies to learn more about their use of cookies and other technology.

You may send an email to info@denalistudios.com for information on how to opt-out of the use of cookies for the delivery of more relevant advertising.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.

Third-Party Services

Our services may contain third party tracking tools from our service providers, such as Flurry and Appsflyer. Such third parties may use cookies, APIs, and SDKs in our services to collect and analyze user information on our behalf. The third parties may have access to information such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geo-location information, and IP address for the purpose of providing their services under their respective privacy policies. Our privacy policy does not cover the use of tracking tools from third parties.  We do not have access or control over these third parties.

Please refer to our list of analytics partners within the Service. You may send an email to info@denalistudios.com for more information on how to opt out of any applicable data collection through these services.

  • Fabric/Crashlytics
  • Appsflyer
  • AppAnnie
  • Facebook

Ad Networks

We may feature advertising within our Service.  The advertisers may collect and use information about you, such as your Service session activity, device identifier, MAC address, IMEI, geo-location information and IP address.  They may use this information to provide advertisements of interest to you.  Please refer to our list of partners below. You may also send an email to info@denalistudios.com for more information on how to opt out of any applicable data collection through these services.

  • Ironsource
  • Unity Ads
  • Applovin
  • Chartboost
  • Vungle
  • AdMob
  • Tapjoy

In addition, you may see our games advertised in other services.  After clicking on one of these advertisements and installing our game, you will become a user of our Service.  In order to verify the installs, a device identifier may be shared with the advertiser.

Links to Other Websites

Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from our Sites. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not part of our Sites, we are not responsible for their content, any use of those websites, or the privacy practices of any of those websites.

Security

Denali maintains administrative, technical and physical safeguards 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, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems.

Access to Personal Information

If your personal information changes, or if you no longer desire our service, you may correct, update, or delete inaccuracies by making the change within your account settings or by contacting us at info@denalistudios.com.  We will respond to your access request within 30 days.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you the Service.  If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at info@denalistudios.com.  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How We Protect Children’s Privacy

We encourage parents to instruct their children about privacy and the way they use their information on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission.

We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age.

If we consider that any of our services are directed at users under the minimum legal age required in their country of residence, we can block such users from using the Services or from providing information and/or limit the collection of information from such users are more particularly described below. No personal information should be submitted to Denali Publishing by users under the minimum legal age required in their country of residence. We apply the following limitations to personal information collection for a user that is not of the minimum legal age required in their country of residence.

Such users cannot:

  • Display his/her real name or any freely entered text in the games.
  • Access in-game chat or SNS (Facebook, etc.).
  • Subscribe to newsletters.
  • Use any feature where users could appear under their real names.
  • Be exposed to advertisements unregulated by COPPA and GDPR requirements.

Children can be invited to take part in our games (playtesting) with their parents’ authorization and/or their parents’ physical presence being required depending on the country where the playtest is conducted.

Opting Out of Marketing

You may opt-out of receiving promotional emails from us by following the instructions in those emails by emailing us at info@denalistudios.com.  If you opt-out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

You may also opt-out of receiving SMS notifications from us, either via SMS or by emailing us at info@denalistudios.com.

International Transfer

Personal information that you provide to us and that we collect may be stored on servers, databases and with third-party service providers in the United States and other countries whose data protection laws may differ from the jurisdiction in which you live. When we transfer personal information from the EU, we put in place appropriate safeguards, such as standard contractual clauses, to ensure the safe and secure transfer and handling of such information. If you would like to learn about our cross-border data transfer mechanism, please contact us at info@denalistudios.com.

Your California Privacy Rights

Pursuant to California Civil Code Section 1798.83(c)(2), Denali does not share your personal information with third parties for those third parties’ direct marketing use.

If you are a California resident under the age of 18, and a registered user of any Site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to info@denalistudios.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Notice to Individuals Located in the EU

If you are located in the EU, you have certain rights with respect to your personal information. If you would like to exercise those rights, please contact us at info@denalistudios.com or through one of the methods listed in the How to Contact Us section.

Legal Basis for Processing

We will rely on one of the following legal bases for processing your personal information:

  1. You have consented to the processing of your personal information

We will obtain your consent for some uses of your personal information, such as to send you information about our Service. If you consent to our use of your personal information for any purpose, you have the right to withdraw consent at any time by contacting us as described above.

  1. We have a legitimate interest in processing your personal information

Denali has a legitimate interest in processing your personal information for certain business and security purposes and to comply with applicable laws, including, but not limited to, the following:

  • Services development, management, delivery and enhancement;
  • Fraud detection and prevention;
  • Network and system security;
  • General corporate operations;
  • User personalization;
  • Compliance with applicable foreign laws;
  • Communications regarding Services that you have already purchased; and
  • Non-targeted marketing and advertising.

You have the right to object to our processing of your personal information based on our legitimate interests. You can do so by contacting us as described above. However, the processing of some types of personal information is necessary to provide you the Service. Therefore, if you object to certain types of processing, we may not be able to provide you the Service.

Processing is necessary for compliance with a legal obligation

We will process personal information when necessary to comply with an obligation under EU or EU Member State law.

Your Rights if You Are Located in the EU

You have the right to request access to the personal information we have collected about you for the purposes of reviewing, modifying, or requesting erasure of the information. You also have the right to request a copy of the information we have collected about you. In certain situations, you may also request that we restrict or cease processing your information.

If you would like to make a request to access, review, or correct the personal information we have collected about you, please contact us at info@denalistudios.com or through one of the methods in the How to Contact Us section, below.

To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your information.

You will be notified of any actions taken on your personal information in response to a request submitted for modification, deletion, or restrictions on the processing of your personal information.

When data processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal. You also have a right to data portability when the data processing is based on your consent or a contract between you and Denali and the data was processed by automated means. You may exercise these rights by submitting a written request to the address listed below under How to Contact Us.

You have the right to lodge a complaint with the appropriate privacy or data protection regulator in your jurisdiction.

How to Contact Us:

Denali Publishing LLC
9737 Great Hills Trail
Ste 260
Austin, TX 78759

If you have any questions about this Policy, please contact us at info@denalistudios.com.