PRIVACY policy

Last Modified on November 26, 2020

This is the Internet of Elephants Privacy Policy.

We ask that you read this privacy policy carefully, as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information, and on how to contact us and supervisory authorities.

1.  WHO WE ARE

Internet of Elephants Limited (“IoE”, “We”, or “Us”) collects, uses, and is responsible for certain personal information about you, as part of the Wildeverse mobile application, the Safari Central mobile application, the Unseen Empire web and mobile application, the Satellite Stories web application, and other IoE applications, and their corresponding websites: internetofelephants.com, wildeverse.game, safaricentralgame.com, satellitestories.io, unseenempire.com (our “Sites”), (together, the “Service”).

For those in the European Union, we are regulated under the General Data Protection Regulation (“GDPR”) which applies across the European Union (including in the United Kingdom) and we are responsible as Controller of that personal information for the purposes of those laws.

2.  CHILDREN’S PRIVACY

We strive to educate parents and kids about how to appropriately safeguard their privacy when using the Service.

We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”) and similar regulations in other jurisdictions. COPPA requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access or use our Services.

If you are under 13 years of age: We urge you to check with your parents before entering any information through our Site or the Service, such as the Wildeverse app or other IoE apps.

If you are a parent: We recommend that you discuss any restrictions you have regarding your child’s online disclosure of their personal information (as discussed below) to anyone they don’t know.

We will not collect or post information from a child under the age of 13 without the involvement of a parent or guardian. IoE will notify the child’s parent or guardian at the email address provided by the prospective customer, alerting the parent or guardian to the child’s use of the Service and providing instructions as to how the parent or guardian can delete the child’s registration from the Service. IoE does not use personal information collected from children for marketing or promotional purposes, and does not disclose such information to any third party for any purpose whatsoever. In addition, we may limit how we collect, use, and store some of the personal information of EU users between 13 and 16.

3.  THE PERSONAL INFORMATION WE COLLECT

Information collected by us: While providing you with the Service, we collect the following personal information:

  • Your username and mobile device ID are collected when you create an account through the Wildeverse app or our other apps (your “Account Information”).

  • Your name and email address are collected when you sign up for our newsletter or contact us for customer or technical support (your “Contact Information”).

  • Any information you share publicly when you post on the Service’s chat or comment functionality (your “Posts”).

  • Any photographs that you post on the Service’s chat or comment functionality (your “Photos”).

  • Your aggregated gameplay information is collected automatically when you use the Service, and crash reports are sent to us when your device crashes while using the Service (together, your “Gameplay Information”).

  • Your location will be collected from your mobile device when you use the Wildeverse app and other parts of the Service (your “Location Information”).

  • Your name, email address, shipping address, and demographic information may be collected if you sign up for entry in a contest or sweepstakes that we host on the Service (your “Sweepstakes Information”).

Information shared with us: While providing you with the Service, others may share the following data with us:

  • Analytics: We use Google Analytics and Squarespace analytics on parts of the Service, which shares information about your browser type, access times, pages viewed, IP Address, and activity just before and during your use of the Service with us (your “Analytic Information”). You can read more about this collection and sharing, as well as your ability to opt out, below in the section entitled “Cookies and other Usage Information.”

  • Purchases: If you make a purchase on the Service (such as purchasing in-game content in any of our Services), the platform holder of your device (Apple or Google, for example) that processes your payment will share information about your purchase history, so that we can properly credit you and provide you with any purchases on the Service (your “Purchase Information”).

  • Kickstarter: If you back one of our crowdfunding campaigns on Kickstarter, certain information about your backer pledge will be shared with us by Kickstarter, BackerKit, and other related companies, in order to fulfill our commitment to deliver backer rewards, but not for other marketing purposes.

  • Events: If you participate in events hosted by us, Eventbrite or other event organization sites may provide us with your name, email address, and other information related to the event.

4.  HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information as follows:

  • Your Account Information is used to set up your account on the Service, to communicate with you about Service-related issues and provide customer and technical support (including receiving and responding to communications that you send us through the Service), to send administrative and promotional messages, and to administer contests and sweepstakes through the Service.

  • Your Contact Information is used to send you newsletters and promotional materials, to communicate with you about Service-related issues and provide customer and technical support (including receiving and responding to communications that you send us through the Service).

  • Your Posts are used and displayed publicly on the Service when you make posts using the Service’s chat or comment functionality, including to other users of the Service.

  • ·You may share your Photos through the Service to social networks and other online methods (such as email, etc.).

  • Your Gameplay Information and Analytic Information is used to ensure the proper operation of the Service on your device and to analyze and improve the Service. To achieve this, we may make your Gameplay Information and Analytic Information non-personally identifiable by either combining or aggregating it with information about other users, or by removing characteristics (such as your IP address) to make it anonymous.

  • Your Purchase Information is used to process purchases made on the Service, keep records of those purchases, and to ensure that those purchases are properly credited to you.

  • Your Location Information is used to allow the Wildeverse app to function, as it is a location-based application, and to populate localized leaderboards and display localized advertisements within the Service.

  • Your Sweepstakes Information is used to administer contests and sweepstakes on the Service, to confirm eligibility, and to ship prizes to winners. Participation is voluntarily. We may use a third party to co-sponsor or to assist us in administering contests and sweepstakes, as well, and share this information with them as part of that administration.

5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We share your personal information with certain third parties in operating the Service. This data sharing enables us to provide you with all of the Service’s functionality.

Some of those third party recipients may be based outside the European Economic Area — for further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to above and the section entitled “Transfer of your Information out of the EEA,” below.

We share your personal information with the following third parties:

  • Newsletters and Beta Testing: We use MailChimp to manage our newsletter and other communications related to the Service, as well as to administer beta tests of new parts of the Service that you sign up for. You can view MailChimp’s privacy policy here. If you would like to unsubscribe from any email newsletter, you can also click on the unsubscribe button or link at the bottom of each email newsletter.

  • Advertising: We share your Location Information with Game Sparks Technologies Ltd. to personalize advertisements based on your location. You can view the Game Sparks privacy policy here.

  • Other Sharing: In addition to the above, we will share your personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of IoE, its employees, clients, or users of the Service.

  • Social Media Functionality: The Site includes certain Social Media Features, such as the Facebook Like button and Widgets for Twitter, Pinterest, and Instagram, such as the “Share this” button or interactive mini programs that run on the Service. These Social Media Features and Widgets are either hosted by third party social networks or hosted directly on the Service. IoE does not have access to this social media data.

  • Your interactions with these Social Media Features are governed by the privacy policy of the company providing it. If you like, pin, tweet or otherwise engage with the Service through a social media channel, you will need to contact that provider directly in order to request removal of personal information. These third parties may set a cookie to enable the feature to function properly.

We will not share your personal information with any other third party.

6.  HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will keep your personal information for the length of time required to provide you with the Service, or until you request its deletion, unless a longer retention period is required by law. Afterwards, we delete all such data in our possession within a reasonable timeframe.

We do not verify the correctness of personal data that we collect or that you provide.

Please note that some data may be retained, if necessary, to resolve disputes, enforce IoE service agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of the Service.

7.  REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION

The laws in certain jurisdictions require that we notify you of the lawful basis for collecting your personal information.

To the extent that such laws apply, we rely on the following as the lawful basis on which we collect and use your personal information:

  • Consent: We rely on your implied or explicit consent for the collection, processing, storage, transfer, and disclosure of your Account Information, Contact Information, and Location Information.

  • To fulfil our contractual obligations: In order to fulfil our contractual obligations to you, either in providing the Service functionality or fulfilling purchases, we must collect, process, share, and store your Account Information, Contact Information, Posts, Photos, Analytic Information, Gameplay Information, Location Information, and Purchase Information.

  • Furtherance of legitimate interests: We may collect, process, store, transfer, or disclose your personal information in furtherance of those legitimate interests of ours which are not overridden by your interests or fundamental rights and freedoms as set forth in the applicable laws. These legitimate interests include, but are not limited to, (i) providing you with the Service, (ii) protecting our users, staff, and property from fraud and other harm, and (iii) collecting information on how you use the Service in order to optimise the functionality of the Service.

  • Legal compliance: We may collect, process, store, transfer, or disclose your personal information to comply with our legal obligations.

“Do Not Track” Signals: Because there’s not yet a consensus on how companies should respond to web browser-based or other “do not track” mechanisms yet, we do not respond to web browser-based do not track signals.

8.  COOKIES AND OTHER USAGE INFORMATION

“Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we employ cookies in certain areas of the Service to allow us to provide information to make your online experience more convenient and to enhance your experience with the Service. Cookies are not spyware or adware, and can’t deliver viruses or run programs on your computer. A user may configure his or her web browsers to accept or reject or delete the cookies, or notify the user when a cookie is being set.

We use these technologies on the Service for the purpose of tracking users of the Service for marketing purposes, as follows:

1) Google Analytics: We use Google Analytics, a web analysis service of Google. Google will analyze your use of the Service anonymously on our behalf. This information collected by Google will be transmitted to a server of Google in the United States, where it will be stored and analyzed.

The results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address, or any other personal information, during this process. Google’s collection and use of information is subject to Google’s Privacy Policy. If you would like to opt out of Google Analytics tracking, please visit one of the following links:

o   Google Ads Settings (http://www.google.com/settings/ads),

o   the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/), or

o   NAI’s consumer opt-out (http://www.networkadvertising.org/choices/).

2) Squarespace Analytics: We also use our Site’s web host, Squarespace, to generate Site usage analytics. You can view their privacy policy here.

9.  TRANSFER OF YOUR INFORMATION OUT OF THE EEA

Internet of Elephants is based in Kenya. No matter where you are located, you consent to the processing, transfer, and storage of your information in and to Kenya.

The laws of Kenya governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

If you would like further information, please contact us (see “How to contact us” below).

10.  EU RESIDENTS - YOUR RIGHTS

Under the GDPR, EU residents have several important rights free of charge, including the right to:

·      Fair processing of information and transparency over how we use your use personal information

·      Access to your personal information

·      Require us to correct any mistakes in your information which we hold

·      Require the erasure of personal information concerning you in certain situations

·      Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

·      Object at any time to processing of personal information concerning you for direct marketing

·      Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

·      Object in certain other situations to our continued processing of your personal information, or otherwise restrict our processing of your personal information in certain circumstances

If you would like to exercise any of those rights, please:

  • Email us at support@internetofelephants.com

  • Give us enough information to identify you

  • Show us proof of your identity (a copy of your driving license or passport, for example)

  • Let us know the information to which your request relates

11. UPDATING YOUR INFORMATION – FOR NON-EU RESIDENTS

You may update the information that we hold about you by emailing us at support@internetofelephants.com.

We strive to help parents ensure that their kids have a safe experience using the Service. Parents or legal guardians can review any personal information collected about their child under 13 years of age, have this information deleted, request that there be no further collection or use of their child’s personal information, and allow for our collection and use of their child’s personal information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.

12. KEEPING YOUR PERSONAL INFORMATION SECURE

We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way.

These include:

  • Limited access to your personal information only to those who have a genuine business need to know it through access controls.

  • Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

  • We use SSL on our Site and any Account Information is encrypted at rest and in transit to protect transfers and storage of your personal information.

  • Additionally, we never ask you for your passwords and we advise you never to enter your account name or password into an email or after following a link from an email.

Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems.  While we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. 

We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, we cannot guarantee its absolute security.

However, we have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13. HOW TO RESOLVE DISPUTES

We hope that we can resolve any questions or concerns you raise about our use of your personal information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.

If you are an EU resident, the GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

14. CHANGES TO THIS PRIVACY POLICY

Our privacy policy was first published on June 11, 2018 and was last updated on November 26, 2020.

We may change this privacy policy from time to time. When we do, we will inform you via a message on the Service or via email, if you have provided us with Contact Information.

15. HOW TO CONTACT US

Please contact us if you have any questions about this privacy policy or the information we collect and store from you.

Please send us an email (support@internetofelephants.com) or write to us at
Internet of Elephants Ltd, PO Box 00479-00606, Nairobi, Kenya.

Our physical address:

Internet of Elephants Ltd. 
The Foundry, Viking House 1st Floor
Nairobi, Kenya