Last updated: 17 April 2020
HOW DOES DOT DOT FIRE HANDLE CHILDREN’S INFORMATION?
1. Children’s Use of the Platforms
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:
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.
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.
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
a. Log Files
These are files that record events that occur in connection with your use of the Platforms.
c. Pixels (also known as web beacons)
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?
1. Service Providers
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.
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
2. Third Party Features
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 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
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.
b. Do Not Track
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.
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?
HOW DO I CONTACT DOT DOT FIRE?
By mail: Dot Dot Fire Limited, Room 1107, Hong Kong Plaza, 188 Connaught Road West, Hong Kong
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
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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