Last modified: July 24, 2020
Dramaton Ltd. (“Dramaton”, “us” “we”, “our”) are committed to maintaining the privacy of our users (“user”, “you”). The following information describes how we collect and process information about you when you use our application (“App”).
Note to Parents
The U.S. Children's Online Privacy Protection Act (“COPPA”) and the regulations implementing it (the “COPPA Rule”), require that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age (“child” or “children”), and that we obtain the consent of parents and guardians in order for children to use certain features of our App, when we use the term “parent” below, we mean to include legal guardians.
Dramaton has developed this App to be an enjoyable experience for our users, including children. We recognize the need to provide further privacy protections with respect to personal information (as will be defined hereunder) that we may collect from children on our Apps and structured the features to minimize the requirement to collect personal information, and to maximize your control over the collection, use and disclosure of any personal information.
Using Our App via Your Device
Types of Information We Collect
Information from which you can be personally identified may also be collected, including but not limited to your name, email address, telephone number or user name and the location of the Device through which you use the App (hereinafter: “Personal Information”). When anonymous information is directly or indirectly associated with Personal Information, this anonymous information also is treated as Personal Information. The App will only collect Personal Information with parental consent or where the parent voluntarily provides it.
How We Collect Your Information
Dramaton offer a variety of activities, including activities that may collect information from children. We may collect Personal Information when you use the App, including without limitation, to play our games or using game-related services, watch advertisements within our App, email us, make a purchase within our App, create user-generated content, and share or contribute to social-media channels.
Below we detail potential instances of collection. In the event we discover we have collected information from a child in a manner inconsistent with applicable laws requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
Content Generated by a Child
Certain activities on our App allow children to create or manipulate content and save it on their Device, post the content publicly on social networks or share it with a third party for the third party’s own use. Examples of created content that may involve the collection of Personal Information are:
We may use your child's information provided by the parent or with the parent's consent to allow your child to send questions or requests to customer support.
We may collect and store your Device's source IP address which may disclose the location of your Device, or take other applicable measures in order to disclose your Device’s location, all provided and subject to the App being installed on your Device. Advertisements and certain content related to our App could be directed to you as a result of this information.
Information We Obtain From Our Affiliates
We may obtain information such as your social media account or user name if you decide to connect to a third-party social network (such as Facebook or Instagram). Your Personal Information will be collected by our billing partners if you make an in-game purchase. Please note that we only sell Dramaton in-app virtual items related to the applicable App, and we don't sell or market any third-party products. If making such a purchase, your credit card or other payment information will be collected and processed by the third-party service provider (e.g. Google Play, Apple App Store), but will never be passed on to us.
Use of Information
We use the Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.
We process the Personal Information where it is necessary for the adequate performance of the contract regarding the requested services available via the App.
We process this information in light of our legitimate interest in improving the App, to allow our users to have the best experience.
We may use your information to detect and prevent fraud, abuse and security incidents in the following ways;
We process this information in light of our legitimate interest in improving our App and enabling our users to engage in a secure environment.
We process this information in light of our legitimate interest to personalize your experience and customize our content.
Disclosure of Information and Transfer of Data
In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties. We may as well share your Personal Information with our affiliates, subsidiaries or any third party service providers and individuals to facilitate the services of our App or any portion thereof, such as marketing, data management or maintenance services. We may also share your information with analytics service providers for analytics services. Such analytics service providers set their own cookies or other identifiers on your computer, through which they can collect information about your usage of our App. This helps us compile aggregated statistics about the effectiveness of our App.
We disclose information to the following third parties:
We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal obligation or inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the App to perform an unlawful act or omission or take any act or omission that may damage Dramaton, its property and goodwill, or if there is an attempted breach of the security of the App or a physical or property threat to you or others. The authority supervising such activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.
You have the right at any time to request to access or modify your information. To exercise these options, please contact us at firstname.lastname@example.org.
In some jurisdictions, in particular those located within the European Union (the "EU") or within the European Economic Area (the "EEA"), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:
Generally, with regard to information collected on our App, Dramaton is a "Data Controller". Therefore, if you wish to exercise the above mentioned rights, please contact us, and we will make our best efforts to fulfill your request.
If you wish to file a request regarding any of the above, you may contact us at: email@example.com.
Exercising the Rights of Your Child
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 you are the parent of a child who is under 13 years of age (or under another age specified by applicable regulations) you may at any time, contact our customer service department to access, change or delete the Personal Information that we have collected from your child by emailing us at firstname.lastname@example.org.
Opt In or Opt Out
You are always in control of your data/personal information, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to email@example.com. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.
Links to Other Websites
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
CAN SPAM Act
The CAN-SPAM Act is a Federal US law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
To be in accordance with CAN-SPAM, we agree to the following:
We deploy industry standard, or better measures to ensure the security, confidentiality, integrity and availability of personal data we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Information on a ‘need to know’ basis for the provision of services to you. No such measures are perfect or impenetrable. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our site or to group companies, and transmission is at the users own risk.
Generally, Dramaton does not retain information longer than necessary to provide its services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your data, we will erase your Personal Information from our systems, unless the data is required for Dramaton to establish, exercise or defend against legal claims or it is necessary for the performance of the requested services.
Governing Law and Jurisdiction