2. Information We Collect and How We Collect It
your first and last name;
your age or birthday;
your e-mail address; your phone number;
and/or other information that helps us make sure it’s you accessing your account or helps us improve our services.
We may also let you create a player profile that other Beluga players can see. Your player profile may include information like:
your profile photo;
your first and last name;
your Beluga username;
the approximate physical location information that you provide;
details about the games you play;
and/or a Beluga username that is created to identify your game account.
When you use our Services, we’ll collect information about the ways in which you use and interact with our Services, such as when and for how long you play our games, game features and other players you interact with, purchases you make, progress or levels you achieve, and other gameplay activities.
3. How We Use Information We Collect and Our Legal Bases for Processing It
We use your information to provide, personalize, maintain the security of, and improve the Services you use; to maintain our business operations; and to exercise, defend or establish our rights.
We use your information under several legal bases, including to perform our contract with you, for our legitimate business interests, to comply with our legal obligations, or otherwise with your consent.
The main use of the information we collect and store is to provide you with the Services you request from us and to improve your gaming experience, but there are other uses as well. The uses for which we collect and store your information include:
to improve and optimize our Services and our players’ experiences;
to create your game accounts and allow you to play our games;
to communicate with you about the Services you’re using, including in-game updates, new Services, and promotional offers that we think might be of interest to you;
to enable players to communicate with each other;
to provide technical support and respond to player inquiries;
to protect the safety and well-being of our players;
to protect Beluga’s rights and property in connection with our Services;
to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
to manage and deliver contextual and behavioural advertising;
to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and/or
to conduct research.
In some cases, we may also have a legal obligation or need to collect information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, another player).
If we ask you to provide information to comply with a legal requirement or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your information (for example, when we ask you to provide a username to access our Services, this will be to create an account for you in accordance with our Terms of Service), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing information is mandatory.
Similarly, if we collect and use your information in reliance on our legitimate interests (or those of any third party), it will be made clear to you at the relevant time what those legitimate interests are (such as personalizing our services and marketing, for example).
If you have questions or need further information about the legal bases on which we collect and use your personal information, please Contact Us.
4. How We Share Information
We’ll share your information with third parties when you use our Services under the circumstances described in this subsection.
We’ll share some of your information with your friends and other Beluga players that you’re playing with to facilitate your gaming interactions with them.
We may share your information, including personal information, with third parties or allow third parties to collect this information from our Services.
We’ll share some of your information with advertisers to tailor the advertisements you see when you use our Services to your interests and to enable us to offer some of our Services for free.
We use advertising to enable us to offer some of our games, game features, and other Services for free. These advertisements may include, without limitation, banner ads on game boards or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer to provide virtual currency or other in-game items to players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, completing a survey, or finishing a particular game level. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Beluga.
We do not actively share personal information that directly identifies you with third-party advertisers for their direct marketing purposes unless you give us your consent.
To enable advertisers, ad networks, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:
performance data (like the number of clicks on an advertisement);
certain technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
a unique identifier, such as your Beluga username; and/or
other contextual data about your game play (like your level and session length).
In addition to serving you with relevant ads, the information collected may be used to:
measure how effective ads are;
offer you targeted advertising (both on and off our Services) in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as interest-based advertising or behavioral advertising); and/or
undertake web analytics to analyze traffic and other player activity to improve your experience.
Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Beluga.
Please note that the practices of third-party companies delivering advertisements on our Services are subject to those companies’ own privacy policies.
Safety, Security, and Compliance with Law
We’ll share your information if necessary for safety, security, or compliance with law.
Your information, and the contents of all of your online communications in our Services and between you and Beluga may be accessed and monitored as needed to provide our Service and may be disclosed:
to satisfy any laws or regulations that apply;
when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
when we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
to protect the rights or property of Beluga or applicable third parties, including to enforce our Terms of Service.
Third-Party Service Providers
We’ll share your information with the third-party service providers and business partners that we work with to bring you our Services.
We will share your information with third-party companies who perform services on our behalf, like payment processing, analytics, analysis, hosting services, customer service, marketing, and advertising optimization. We will also share your information with our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple or Google, etc.). Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information (as required by applicable data protection laws).
In the case of a sale or merger, we’ll share your information with the interested party if we undergo or evaluate undergoing a sale or merger.
We may share some of your information with other third parties if we have your consent to do so.
5. Your Rights and How to Access, Update, and Manage Your Personal Information
You can request a deletion of your personal information by submitting a request through our contact us section.
You can correct or update your personal information, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
You can opt-out of marketing communications we send you by following the instructions in “Opting Out of Promotional Communications from Beluga” below.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We respond to all data protection requests we receive in accordance with applicable data protection laws.
To review and update personal information associated with your Beluga player profile, visit the “settings” and “profile” pages.
If you want to review or delete personal information associated with your game account data, please submit a request through our Contact Us form.
For deletion requests, we will take reasonable measures to delete your personal information from our records. If you have sent content through or posted content on the Service, we may not be able to delete it. We will keep certain records (e.g., personal information relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We’ll also keep information in order to exercise, defend, or establish our rights.
You can opt out of mobile push notifications in your device’s settings page.
If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device’s “settings” page. Many of our games also offer the ability to turn off push notifications in the in-game “settings” page.
You can opt out of third-party behavioral advertising through your device settings and other third-party opt-out tools.
6. Privacy Policies of Linked Third-Party Services and Advertisers
We aren’t responsible for the ways in which third parties use your information (other than our service providers acting under our instructions).
Our websites and games may contain advertisements from “Third-Party Services,” meaning companies other than Beluga, that may link to their own websites, online services, or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.
7. Our Policies Concerning Children
We seek to ensure that we do not collect information from children.
Generally speaking, most of our Services are not intended for children under the age of 18 (collectively, “Children”). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.
Though our Services do not target Children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as Children in our age-gate on such Services, if we allow Children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA, or obtain legally valid parental consent.
If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that information from our records.
8. How Long We Keep Your Information
We’ll keep your information for as long as necessary to provide you with the Services, maintain our legitimate business operations, and/or exercise, defend or establish our rights.
How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.
We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.
9. Security of Your Information
We work hard to protect your information but you also have a role to play.
If you have an account registered with Beluga, your profile information is protected by the password you use to access your Beluga account. It is important that you protect and maintain your Beluga account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your Beluga account, the Services allow you to request that instructions be sent to you that explain how to reset your password. We urge you to log out of your Beluga account when you are finished using it.
When you sign into your Beluga account or enter payment information, we and our third-party payment processor use encryption to transmit that information.
While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please Contact Us.
10. California Residents
If your a California resident, you have certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). Our California Privacy Notice specifies these rights, check it out here.
12. Contact Us
You can contact us with your questions, comments, or concerns.
. There is a link to contact us in the help section on the Beluga application.