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Privacy Platform Policy

Turiya Media, Inc. (DBA Playnomics)

Last Updated: 2012/06/14

OVERVIEW

Welcome to our websites, playnomics.net and playnomics.com (“Site”), owned by Turiya Media Inc., doing business as Playnomics (“Playnomics” or “we” or “us” or “our”). We operate a digital marketing system and service (“Service”) that allows publishers (“Publishers”) of web-based games and other Internet-connected games and applications, including games and application that run on mobile devices (collectively, “Applications”) to manage and customize the experience of specific Application users (“Users”).  The Service also allows Publishers and other customers of ours to display advertisements to Users and others when they browse the web that are more likely to be relevant to them and to measure the effectiveness of such advertisements.

Our Service primarily uses data generated by Users’ interaction with Applications, such as how often and for how long a User plays a game and what in-game purchases or other in-game activities the User engages in. We do not intentionally collect, store, or share the personally identifiable information of any User, with the exception of User demographics information (such as country, city, gender, and birthday) that Publishers collect through their relationship with Users and provide to us. We also collect the IP address of the computer system or device the User is using and the Users’ anonymous identifier(s) associated with the Application (i.e. not the Users’ name, social security or other such personal identifier that is independent of the interaction with the Application).

ADVERTISING OPT-OUT

Please go to http://www.playnomics.net/privacy-issue.html and follow the instructions if you want to opt-out of our use of information we collect for purposes of serving you more relevant advertising.  Clicking this link will cause a cookie to be placed on your system that tells the Service not to use collected information for the purpose of serving advertising.  Note that opting-out will not cause you to see fewer advertisements when you browse the web, it only means that advertisements you see that are served by Playnomics are less likely to be of interest to you.  Please also note that this opt-out will not stop the collection, use or disclosure of data for purposes of allowing a Publisher to manage and customize your experience when you use that Publisher’s Applications or for other purposes outlined in this Policy.

For more information regarding the use of cookies and other technologies for advertising purposes, please click on the links found below under the heading “Third Party Advertising Service Providers.”

WHAT WE COLLECT

Our Service collects data about all aspects of Users’ experience in and interactions with games and other Applications. Categories of this data include:

User visits to Applications that use our Service are typically logged in our servers, which record the time, IP address, device operating system, browser information and other technical information, referrer (current, previous, or parent browser page) and the server request. Most interactions with Playnomics servers will generate and place or update a cookie with a unique ID. Web sites and Applications using the Service may share such ID, allowing Playnomics to potentially link and identify (non-personally) a User across multiple websites and Applications.

Publishers may also share with Playnomics the User’s self-reported demographic information, such as country, city, gender, birthday and list of friends.

We also collect data regarding the performance of advertisements that we serve, such as the number of unique views an advertisement receives, when it is viewed and the number of times it is clicked on.  We may also record data on how many time an individual browser is served a given advertisement in order to place a limit on how many times the same advertisement is displayed or to display advertisements in a certain sequence.  Our third party advertising service provider may collect this data on our behalf for these purposes.

HOW WE COLLECT DATA

Publishers include in their Applications certain software code provided by Playnomics that enable Playnomics, among other things, to place cookies on your computer system or device and use pixel tags, beacons and other tracking technologies.  This software also provides to Playnomics a unique alphanumeric string associated with the User’s specific installation of the Application. Using these technologies, Playnomics receives “events” input from the Users’ device and/or the Publisher’s servers about Users’ activities in Applications and websites, as well as other data as described above. This data is stored on the Playnomics servers, where we analyze it for the marketing activities described below. We retain this data for each User until such time as at least three (3) years elapses without our server receiving any new activity information regarding that User.

A Publisher may also choose to provide information to Playnomics that is collected directly by or on behalf of the Publisher, instead of or in addition to allowing Playnomics to collect information through use of Playnomics software code as described in the preceding paragraph. We will use pixels and cookies in connection with the advertisements that are served by us or on our behalf in order to measure the delivery and performance of such advertisements as described above.

WHAT WE DO WITH THIS DATA

We use the data we collect to develop and improve the Service, to help Publishers deliver a more customized experience to each User and to help Publishers, advertisers, agencies and ad networks place and measure the effectiveness of ads in the Applications and elsewhere on the web. Examples include, but are not limited to:

HOW WE SHARE USER DATA

We may share with selected third parties aggregated User data (such as behavioral trends by categories), in a form that is not personally identifiable. We may also share User data (individual or aggregated)  with the Publisher of the Application from which the data was gathered.

References to the “Playnomics servers” or “our servers” that store data may include servers and facilities provided to us by third party vendors for the operation of our Service.

In addition, any data may be transferred as part of any merger, acquisition, debt financing, sale of company assets or similar transaction, as well as in the event of insolvency, bankruptcy, or receivership in which information could be transferred to third parties as one of our business assets.

We also reserve the right to disclose any information that we believe, in good faith, is appropriate or necessary: to take precautions against liability; to protect us from fraudulent, abusive, or unlawful activities; to investigate and defend ourselves against third-party claims or allegations; to assist government enforcement agencies; to comply with legal process, such as a subpoena; to protect the security or integrity of the Services; or to protect the rights, property, or personal safety of any person or entity.

THIRD PARTY ADVERTISING SERVICE PROVIDERS

In addition to the data that Playnomics collects or that is received from Publishers, Playnomics may partner with third party advertising companies who may collect data through cookies, beacons and other technologies in order to deliver more relevant advertising, to predict characteristics or interests and to measure the performance of advertising campaigns.  Such third parties may provide us with data or services that we use to assist us in delivering or measuring the effectiveness of advertising.  We may also provide data that we collect or receive to such third parties so they can assist us in delivering or measuring the effectiveness of advertising.

For more information about this, including the opt-out choices made available by such third parties, please visithttp://www.networkadvertising.orghttp://www.aboutads.info and http://preferences-mgr.truste.com.

UPDATES TO THIS POLICY

We may occasionally update this policy. When we do, we will also revise the “Effective Date” at the beginning of the policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose information.

CONTACT

The address of the entity responsible for this policy is:

Business name: Turiya Media Inc.
Street Address: 139 Townsend, Suite 250
City: San Francisco
State or Province: California
Postal Code: 94107
Postal Address Name: Turiya Media Inc.
Email Address: privacy@playnomics.com

DISPUTES AND REMEDIES

To discuss and resolve any privacy-related dispute you may feel you have with us, please contact our privacy customer service representatives at privacy@playnomics.com

ADVERTISING LINKS

Advertisements we deliver, as well as any marketing messages delivered within an Application by us or on our behalf, promote products and services offered by Publishers other third parties.  If you choose to click on any such advertisements or purchase or use any such products or services, please be aware that this policy will not apply to your activities or any information you disclose in connection with your interactions with such third parties.  We encourage you to contact the applicable third parties for information regarding their privacy policies and practices.

CHILDREN

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. We do not knowingly collect personal information from children under the age of 13.

INTERNATIONAL USERS

Our Site and Services are hosted and operated in and/or controlled from the United States and are generally intended for United States users. If you visit from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please be aware that you are transferring your information to the United States. The United States does not have the same data protection laws as the EU and some other regions. By providing any information (whether personally identifiable or not) to us, you consent to its transfer to the United States and the use of it in accordance with this policy.

SECURITY

We use reasonable security measures that are designed to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any personal information or other information.