Dot Dot Fire Privacy Policy

Last updated: 17 April 2020

INTRODUCTION

 

This Privacy Policy (the “Privacy Policy”) describes how Dot Dot Fire Limited, Room 1107, Hong Kong Plaza, 188 Connaught Road, Hong Kong (“Dot Dot Fire”, “we”, “our” or “us”) collects, uses and discloses information about you as well as your rights and choices about that use and disclosure, and applies to your use of the www.dotdotfire.com website (the “Sites”), the mobile and personal computer software applications published by Dot Dot Fire (the “Apps”) and the programs offered by Dot Dot Fire through the Sites (the “Programs”). In this Privacy Policy, the Sites, Apps and Programs are referred to collectively as the “Platforms”. This Privacy Policy does not apply to the collection, use or disclosure of information through any apps for which Dot Dot Fire is not the publisher.

 

By using the Platforms, you signify your assent to our Privacy Policy, the collection, use and disclosure practices, and other activities described therein. If you do not agree, discontinue any use of our Platforms. In case of discrepancies between the English version and any other versions of this Privacy Policy, the English version shall prevail.

 

CHANGES TO THIS PRIVACY POLICY

 

We reserve the right to make changes to this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Please check the Privacy Policy each time you use our Platforms to ensure you are aware of any changes in our privacy practices. Our Privacy Policy will indicate the date it was last updated. Your continued use of our Platforms will signify your acceptance of the changes to our Privacy Policy. If there is a material change in the way that we use your information under this Privacy Policy, we will notify you via email of the relevant changes or provide other prominent notice on our Sites and/or Apps.

HOW DOES DOT DOT FIRE HANDLE CHILDREN’S INFORMATION?

 

1. Children’s Use of the Platforms

 

Dot Dot Fire has developed its Platforms to be an enjoyable experience for users of all ages. Some parts of the Platforms are primarily targeted at children, such as some of our Apps, while others are intended for parents and educators, such as our Sites. Whenever we refer to “children” in this Privacy Policy, we mean children under the age of 13, unless otherwise indicated.

 

Dot Dot Fire complies with the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children. Dot Dot Fire takes precautions designed to protect the online privacy of children, and we encourage parents to take an active role in protecting their children’s privacy by discussing this Privacy Policy with them. If you are a data subject in Europe and have a child under the age of 16, please see the What Should I Know as a Data Subject in Europe? section below.

 

If you have any questions or comments about how we treat children’s information or our compliance with COPPA, please contact us as set out in the How Do I Contact Dot Dot Fire? section. If you would like to learn more about COPPA, you read about the rule on Federal Trade Commission’s website (https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule).

2. Collection, Use, and Sharing of Information from Children

 

We collect, use, and share personal information from children through our Platforms as follows:

 

a. Registration

 

For our Platforms, Dot Dot Fire may age screen users in accordance with COPPA and, where Dot Dot Fire identifies a child user, seek verifiable parental consent in accordance with COPPA to the collection, use and sharing of personal information as otherwise set out in this Privacy Policy.

If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

b. Persistent Identifiers

Dot Dot Fire collects, uses and shares persistent identifiers, such as device identifiers or IP addresses, through our Platforms strictly for the purpose of providing essential support for the internal operations of the Platforms or as otherwise permitted by COPPA. This information may be collected by Dot Dot Fire or a third party providing a service to Dot Dot Fire.

c. Advertising

None of Dot Dot Fire’s Platforms incorporate advertising serving technology offered by third party service providers. We use Google Analytics to track and analyze (anonymous) usage data for statistical purposes and optimization of our sites and services. Please note that while our Platforms may contain advertisements about Dot Dot Fire or products and services of our partners, we prohibit behavioral advertising to our Platforms or through data collected from our Platforms.

Subject to our compliance with COPPA, Dot Dot Fire may collect, use, share and otherwise process personal information from children in accordance with this Privacy Policy. We may also seek verifiable parental consent as necessary to comply with COPPA. In either case, we will not collect more personal information from children than is reasonably necessary to participate on our Platforms.

d. Security

 

We take reasonable measures to maintain the confidentiality, security, and integrity of children’s personal information collected through our Platforms, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security. We retain children’s personal information only as long as necessary to fulfill the purpose for which it was collected, and delete such information using reasonable measures to protect against its unauthorized access or use.

e. Parental Choices and Controls

 

As part of the verifiable parental consent process, where applicable, parents and legal guardians will have the choice of consenting to our collection and internal use of their child’s personal information but prohibiting us from disclosing that information to third parties (except to the extent such disclosure is integral to the use of our Platforms). Additionally, any parent has the right to: (1) review, correct, or delete the child’s personal information; and/or (2) discontinue further collection, use, or sharing of the child’s personal information. Please note that exercising these choices may restrict your child’s ability to access certain functionality of the Platforms. To exercise any of these choices, please contact us as set out in the How Do I Contact Dot Dot Fire? section. If you are a parent or guardian and believe that we have collected your child’s personal information in violation of COPPA, please contact us as set out in the How Do I Contact Dot Dot Fire? Section, and we will remove such information to the extent required by COPPA.

 

WHAT INFORMATION DOES DOT DOT FIRE COLLECT?

 

1. Information You Provide

 

Dot Dot Fire collects information that you provide on or through the Platforms, including information you provide when you register for an account on our Sites, purchase our products or services, use our Apps, access our content, participate in a Promotion, subscribe to our newsletters, or contact customer support. We use third party service providers to collect information. The information we collect includes information that can be used to identify a specific individual (whether alone or in combination). Some examples of information you provide include the following: Contact data, including your first and last name, email address, home address, and phone number. Demographic data, including your age, gender, preferred language, country and zip code or postal code. If you are a parent or legal guardian, information about your child such as your child’s first name and last name, year of birth, gender, and country of residence. Content, including content within any messages you send to us (such as provided in surveys or questions to customer support).

You may choose to voluntarily submit other information to us through the Platforms that we do not request, and, in such instances, you are solely responsible for such information.

 

2. Information Collected Automatically

 

Dot Dot Fire automatically collects information about your use of the Platforms to help us improve our services or for other purposes as described in this Privacy Policy. Some examples of information we automatically collect include the following: Service Use Data, including information about online activity such as feature usage, game play statistics and in-app purchases. Device Connectivity and Configuration Data, including information about hardware, software, platform, media, connection data, your internet service provider, and your device’s regional and language settings. This includes device identifiers such as IP address, MAC address, and device identifier. Location Data, including location derived from an IP address or data that indicates a city or postal code level. We do not collect precise location data. We use various current – and later – developed technologies to automatically collect information (“Tracking Technologies”), including the following:

 

a. Log Files

 

These are files that record events that occur in connection with your use of the Platforms.

 

b. Cookies

 

Cookies are small data files stored on your device that act as a unique tag to identify your browser. Use of cookies makes web-surfing easier by performing certain functions such as saving language preferences and maintaining your sessions while you are on our Sites.

 

c. Pixels (also known as web beacons)

 

These are code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We incorporate pixels from third parties that allow us to provide you with additional functionality.

d. App Technologies

 

These are technologies included in our Apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our Apps include third party SDKs, which is code that sends information about your use to a server. These SDKs allow us to analyze the performance of our Apps and provide you with additional functionality. We do not collect information for behavioral advertising.

For more information on the use of Tracking Technologies within our Platform and your rights and choices regarding Tracking Technologies, see the What Should I Know about Third Parties? and What Are My Rights and Choices? sections below.

 

HOW DOES DOT DOT FIRE USE THE INFORMATION COLLECTED?

 

Dot Dot Fire uses the information you provide us for the purposes of:

1. Managing and optimizing our Platforms, including:

 

Enabling your use of our Platforms and access to certain areas of our Sites or Apps; Delivering you customized content; Monitoring and analyzing trends, usage, and activities; and Diagnosing problems with and improving our Platforms.

2. Communicating with you and facilitating your requests, including:

 

Responding to your comments, questions and requests, including providing customer support; Administering Promotions, including verifying eligibility and awarding prizes, which are only directed to adults and non-child users; and Subscribing you to Dot Dot Fire’s newsletter, which may include advertisements and communications alerting you to new products, features and enhancements, special offers upgrade opportunities, and contests and events of interest.

3. Protecting our Platforms and user rights, including:

 

Obtaining verifiable parental consent, as necessary; Preventing and addressing fraud, breach of policies or terms, and threats of harm; and Sending you technical notices, updates, security alerts, information regarding changes to our polices, and support and administrative messages.

HOW DOES DOT DOT FIRE SHARE OR DISCLOSE INFORMATION?

Dot Dot Fire shares the information we collect in accordance with the practices described in this Privacy Policy for the limited purposes described below.

1. Service Providers

 

We transfer information to third party service providers that perform services on our behalf or otherwise collect, use, disclose, store or process information on our behalf for the purposes described in this Privacy Policy (including but not limited to account registration, completing purchases, data analytics, website hosting, and technical support). Some of these service providers may be located in a country other than where you reside, and your information may be stored or processed in those countries. We implement reasonable contractual measures designed to ensure that our service providers provide appropriate protection for your information and use your information only for the purpose of providing the services to us. Your information may be subject to the legal requirements of the country in which it is located, including lawful requirements to disclose information to government authorities in those countries only. Our employees and those of our agents and service providers who require it in order to fulfill their job requirements will have access to your information.

2. Partners

 

Dot Dot Fire shares information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.

 

3. Business Transactions

 

We reserve the right to transfer any information we have about you in connection with the sale or transfer of all or a portion of our business or assets or rights relating thereto.

4. Legal Rights and Obligations

 

We may use and/or disclose your information to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage. When necessary, we may also disclose information to law enforcement, or to the appropriate civil authorities.

5. Consent

 

We may share information to fulfill any other purpose as directed by you or with your consent. Generally, by providing us with information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified at the time that we collect the information from you or as otherwise described in this Privacy Policy. In the case of children under 13, as applicable, we will obtain a parent or legal guardian’s verifiable consent prior to the collection of personal information from such users, unless the collection of such information falls within an exception that is permitted under COPPA.

Notwithstanding the above, Dot Dot Fire may share or disclose information that does not identify you (including information that has been aggregated and de-identified) with third parties except as prohibited by applicable law. For more information on your rights and choices regarding how we share information about you, please see the What Are My Rights and Choices? section below.

WHAT SHOULD I KNOW ABOUT THIRD PARTIES?

1. Third Party Services

 

If you click on a link to a third party site, you will leave the Dot Dot Fire Platform you are visiting and go to the site you selected (“Third Party Service”). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as Dot Dot Fire. We encourage you to review the privacy policies of these third party sites from whom you request services. If you visit a Third Party Service that is linked to on a Dot Dot Fire Platform, you should consult that site’s privacy policy before providing any information on that site.

2. Third Party Features

 

We may offer portions of our Platforms on or integrate portions of our Platforms with Third Party Services (“Third Party Features”). For example, we may offer content on social networks such as a Facebook and Twitter. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our brand on a Third Party Service (e.g., by using a hashtag associated with Dot Dot Fire in a tweet or post), we may use your reference on or in connection with our Platforms. Please be aware that if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use.

3. Analytics and Advertising

 

Our Sites and Apps contain Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics providers, such as Wix, Google Analytics, and Firebase, to help us analyze your use of the Sites and Apps, compile statistic reports on the Site’s and Apps’ activity, and provide us with other services relating to Site and App activity and internet usage.

We do not engage in behavioral advertising on our Platforms. For further information, please see the How Does Dot Dot Fire Handle Children’s Information? section above. For further information on Tracking Technologies and your rights and choices regarding them, please see the What Information Does Dot Dot Fire Collect? and What Are My Rights and Choices? sections.

WHAT ARE MY RIGHTS AND CHOICES?

 

1. Reviewing, Correcting and Deleting Your Information

 

If you wish to request access to certain information you have voluntarily submitted to Dot Dot Fire or request that such information be corrected or deleted, or if you have any questions, comments, or concerns about this Privacy Policy or the information practices of Dot Dot Fire, please contact Dot Dot Fire as set out in the How Do I Contact Dot Dot Fire? section below. Your right to access, correct, or delete your information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

If you believe we have collected and stored any personal information from children under 13 in violation of COPPA, parents or legal guardians can request access to review such information, have it deleted, or stop our further collection or use of such information. To make any of these requests (when applicable), please contact us as set out in the How Do I Contact Dot Dot Fire? section below.

2. Tracking Technology Choices

 

a. Cookies

 

Most browsers accept cookies by default. If you prefer not to receive cookies by default, you can alter the configuration of your browser to refuse or delete cookies.

 

If you would like to view or change the cookies settings of our Site, please see the Cookie Declaration section below.

 

If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. If you choose to have your browser refuse cookies, some areas of our Sites may not function properly.

b. Do Not Track

 

Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Currently, our Sites' system does not support and cannot act on DNT signal headers that we may receive. However, the choices that we provide you concerning collection and use of your information will continue to operate as described in this Privacy Policy. For more information on “Do Not Track,” visit https://www.allaboutdnt.com.

Please be aware that if you disable or remove Tracking Technologies some parts of the Platforms may not function correctly.

c. Analytics and Behavioral Advertising

 

Although our Platforms do not actively engage or promote the use of behavioral advertising, our Sites contain third party tools such as Google Analytics and YouTube. These third party tools collect data through Tracking Technologies such as cookies, which may be used in accordance with their privacy policies. Please refer to the privacy policies of these third parties to learn more about their practices and available opt-outs.

3. Communications

 

a. E-mails

 

You may opt out of receiving promotional emails from us at any time by contacting us as described in the How Do I Contact Dot Dot Fire? section below or by using the unsubscribe mechanism included in the email communications you receive. Please note that you cannot opt-out of non-promotional emails, such as those about your transactions, servicing, or Dot Dot Fire’ ongoing business relations.

Please note that your opt-out is limited to the email address or device used and will not affect subsequent subscriptions.

4. Your California Privacy Rights

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set out in the How Do I Contact Dot Dot Fire? section below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Dot Dot Fire is not required to respond to requests made by means other than through the provided email address or mail address.

5. Your European Privacy Rights

 

Data subjects in Europe have additional rights as set out in the What Should I Know as a Data Subject in Europe? section below.

HOW DOES DOT DOT FIRE PROTECT INFORMATION?

 

We maintain reasonable and appropriate safeguards designed to help protect the security, integrity, accuracy, and privacy of the information you have provided. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. Any personal information provided to us is contained within secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of that information. All sensitive information you supply is transmitted over an encrypted Secure Socket Layer (SSL) connection and passwords are always hashed using security-industry standard hashing algorithms before being stored in our databases.

DOES DOT DOT FIRE TRANSFER INFORMATION INTERNATIONALLY?

 

Our Apps servers are hosted through Amazon Web Services, specifically through their data centers in the United States and Singapore. If you are accessing the Apps from outside of the United States or Singapore, please be aware that information collected through the Apps will be transferred to, processed, stored, and used in the United States, Singapore and other jurisdictions. Data protection laws in the United States and Singapore may be different from those of your country of residence. Your use of the Apps or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the United States, Singapore and other jurisdictions as set out in this Privacy Policy. If your data is collected in Europe, we will transfer your personal data subject to appropriate safeguards, including standard contractual clauses.

HOW DO I CONTACT DOT DOT FIRE?

 

For any comments, questions, or complaints regarding this Privacy Policy or our privacy practices, please do not hesitate to contact us!

By mail: Dot Dot Fire Limited, Room 1107, Hong Kong Plaza, 188 Connaught Road West, Hong Kong

 

By email: support@dotdotfire.com

WHAT SHOULD I KNOW AS A DATA SUBJECT IN EUROPE?

 

1. Dot Dot Fire is a Data Controller

 

Data protection laws in Europe make a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Dot Dot Fire acts as a controller with respect to personal data collected as you interact with our apps, websites, emails, and advertisements.

 

2. Dot Dot Fire has a Lawful Basis for Processing

 

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. We retain personal data for as long as necessary to fulfill the purpose for which it was collected, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

3. Your European Privacy Rights

 

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us. You may exercise your rights by submitting a written request to us at the address set out in the How Do I Contact Dot Dot Fire? section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

 

4. Children in Europe

 

Where the basis for our processing of personal data from children under 16 in Europe is consent, we will make appropriate efforts to verify that consent is given or authorized by the holder of parental responsibility over those children, and, if we learn or have reason to suspect that we have collected personal data from those children without parental consent, we will promptly delete it. If you are a child under 16 in Europe, please speak with your parent or guardian about this Privacy Policy so you can better understand how we use your personal data.

 

5. Complaints

 

If you have a complaint about our use of your personal data or response to your requests regarding your personal data, please contact us via one of the contact methods outlined above.

 
 
 
 
 
 

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Dot Dot Fire International

10 Anson Road

#22-02 International Plaza

Singapore (079903)

Dot Dot Fire Hong Kong

Hong Kong Plaza

188 Connaught Road West

Hong Kong

© 2020 Dot Dot Fire