Glu Mobile Inc. and its subsidiaries and affiliates (collectively, "Glu," "we," "our" or "us") respect the privacy rights of our online visitors and recognize the importance of protecting the information collected about you. We have created this Privacy Policy, which explains what personally identifiable information we collect from you on our web sites (the "Sites"), including without limitation www.glugames.com, www.glu.com, games.glu.com, Glu's fan page on Facebook (http://www.facebook.com/glumobile), Glu's fan pages for specific Glu products, Glu's page on Twitter.com (http://twitter.com/glumobile), and through our mobile and web-based applications and through other means such as Glu newsletters and Glu sweepstakes and contests (the "Services"). This Privacy Policy provides guidance on how we collect, store and use the information you provide through the Services. Please note that this policy does not apply to information collected by or through websites maintained by other companies or organizations to which the Sites may link.
We reserve the right to change this Privacy Policy at any time. Please check this Privacy Policy each time you use the Sites to ensure you are aware of any changes in our privacy practices. Our Privacy Policy will indicate the date it was last updated. We will notify you of any material changes by posting a revised policy on games.glu.com. Your continued use of the Sites will signify your acceptance of the changes to our Privacy Policy.
Glu adheres to the Safe Harbor Principles that were established by the U.S. Department of Commerce in consultation with the European Commission to comply with the European Commission's Directive on Data Protection that went into effect in October, 1998.
If you have any questions, complaints, or comments regarding our Privacy Policy, please contact our Privacy Policy Administrator. You may also contact our Privacy Policy Administrator by writing to: Privacy Policy Administrator, Glu Mobile Inc., 2207 Bridgepointe Parkway, Suite 300, San Mateo, California 94404.
Third Party Web Sites
The Sites contain links to web sites belonging to third parties not related to Glu. When you leave the Sites, our policies, including this Privacy Policy, no longer govern because Glu cannot control the activities of third parties. Any information you provide to these third parties is subject to their privacy policies, which may differ from ours. Glu is not responsible for the actions of those parties, the content of their web sites, collection or use of information you provide to them, or any products or services they may offer. Our link to a third-party web site does not constitute our sponsorship of, or affiliation with, the third party or the third party's web site. We encourage you to review and understand the privacy policies of these third parties before providing personal information to them.
Certain products or services displayed on the Sites are provided to you by third party (such as your mobile service provider). The Sites may contain links to web sites operated by third parties that may be of interest to you. Such products shall identify the third parties on the Sites and/or at point of purchase. If you elect to purchase the products, your personal information will be transferred to such third parties and will be subject to their privacy policies. We are not responsible for the privacy policies of such third parties. You should review their privacy policies prior to providing your personal information in connection with such products.
What is Personal Information and When Does Glu Collect It?
Characteristics of Personal Information
When we use the term "personal information" in this Privacy Policy, we are referring to personally identifiable information that specifically identifies an individual (such as an individual's first and last name, street address, telephone number, e-mail address, credit card or other account number), information about that individual or such individual's activities or preferences when such information is directly linked to personally identifying information and information that may be used to contact you on-line or off-line. Glu uses your personal information to contact you, complete your transactions (as needed), administer your inquiries and provide the Services.
Personal information does not include "aggregate information," which is data we use to create aggregate statistics about our customers and visitors, as well as information regarding sales, traffic patterns, and related web site information from which any personal information has been removed. Aggregate information may include demographic information, such as gender, age or city or town of residence, zip code, information about your hardware, software, platform, Internet IP address and connection, and information about your on-line activity including feature usage, game play statistics and scores, user rankings, click paths, on-line profiles (visible to the public or other users of the Sites) and survey responses. We collect aggregate data for a number of purposes, including tracking trends and understanding user needs so that we can better consider new products and services, and improve the quality and value of existing products and services to suit visitor preferences. We use this information to monitor and analyze use of the Services and the Sites, for technical administration, to increase functionality and ease of use and to better tailor the Sites to our visitors' needs. This policy does not limit or restrict our collection of aggregate information, and we may disclose this information to third parties.
We collect personal information from our visitors during (1) contests and sweepstakes (registration or claiming a prize), (2) during customer support or technical service requests, (3) registration for games or special game-specific event participation, (4) newsletter subscriptions, promotional materials, marketing surveys, email campaigns and other alerts, (5) registration for membership on the Sites, (6) your placement of an order for products or subscriptions from us, (7) your request for services from third party service providers on the Sites or (8) your use of our software or online services. Information collected will vary depending upon the activity and may include your first and last names, e-mail address, home telephone number, mobile telephone number, mobile device type, home address, birth date, and credit card information. Prize winners of contests or sweepstakes may have to provide their Social Security Numbers for tax purposes. We may combine aggregate information and/or demographic information with personal information for the uses described in this Privacy Policy.
We may require personal information to obtain access to some of the Sites; however, where we do not, you may not be able to access certain areas or utilize functions that require registration.
Personal information may also be collected if you provide personal information in connection with interactive features of the Sites or of any mobile or web-based applications, including but not limited to creating a profile, sending a wallpaper image to your phone or inviting a friend. Additionally, information, such as your performance or rank in games ("leaderboards"), or your friends' member names, may be associated with your member name and displayed on the Sites and in our applications and related services.
Some of our mobile applications may require you to input your mobile telephone number or other personal information into the application. We use this information in connection with providing the application, such as to authenticate you and to communicate with you regarding our services by SMS, text message or other electronic means to your mobile device.
Should you choose to participate in on-line discussions or leave comments on the Sites' message or bulletin boards, any information you provide in such forums is public information, and there is no expectation of privacy or confidentiality there. Information you provide in these forums is not subject to this Privacy Policy. You should be advised that supplying information in this manner is done at your own risk. Other users of these forums can view, read, collect or otherwise use your posted information for unintended uses including sending you unsolicited e-mail or other messages. We are not responsible for any of the information you choose to submit in these forums.
If you subscribe to the Glu e-mail newsletter, request support, send us an email, or otherwise contact us through the Sites, we collect the personal information that you supply in such communication. We use such information to fulfill and contact you regarding your request and for other purposes as set forth in this Privacy Policy.
On-line submission of resumes, employment applications and the like are not governed by this Privacy Policy.
Automatically Collected Information
As stated above, when you visit the Sites, we may collect information about your computer, such as your IP address, browser type and operating system version. We use this information to help diagnose problems with our server, to administer the Sites, and to improve our products and services. This information may also be used to gather broad demographic information that does not personally identify you.
When you use some of our mobile or web-based applications, your mobile device or personal computer may transmit information about your activities in the application, as well as information you enter in the application, to our servers. We use this information to provide the service to you, to improve our applications and related services, and to gather broad demographic information that does not personally identify you. We may also use the information to learn about and resolve problems with the application, to improve the application and our other products and services, and to develop new products or services. In addition, if any application includes any location-based services, your location may be shared with us while using such feature.
Other Use of Personal Information
In addition to the specific uses mentioned above, we may use the personal information we collect (a) to contact you about your use of the Sites or the Services, such as for administrative purposes or to provide you with customer service; (b) for the purpose for which it was provided, such as to provide our products and services, to fulfill or respond to your requests and to process transactions; (c) to notify you about important changes to our policies, the Sites or our products or services, (d) to alert you regarding new and existing Glu features, products and services, and special Glu offers, promotions and events that we think you may find interesting and for other internal marketing, informational, product development and promotional purposes if you opt-in or request this type of communication from us; (e) to request feedback and to improve the Sites and our product and service offerings, and develop new products and services; and (f) to provide product support.
We may use survey responses to marketing surveys to select and direct advertising for Services that are more likely to be of interest to you. Participation in marketing surveys is entirely optional. We may share aggregate consumer data (which does not contain personal information) with the advertising companies. However, we do not disclose your personal information to our advertisers without your consent, and we do not disclose any personal information about children under 18 years of age who have registered on the Sites to any third parties, regardless of parental consent, or use, share or disclose such personal information other than as set forth in this Privacy Policy.
Finally, we may use your personal information for our internal marketing and demographic studies, so we can consistently improve the Sites to better meet your needs.
Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives.
Opt-In Provision
Generally, we do not share your personal information with third parties, except as described by this Privacy Policy. However, if we intend to share such information with more third parties, we will ask you to opt-in or consent to sharing your personal information with parties outside of Glu (except to the extent required by law, court order, or as requested by other government or law enforcement authority) when we first collect information about you. In addition, if you do not want us to send you e-mail or postal mail about our products and services, you can choose not to opt-in at the time of registration or information collection. If, at a later date, you choose to have your name removed from our mailing list, you can do so by unsubscribing as directed in the newsletter, or by contacting our Privacy Policy Administrator. You may also click the unsubscribe link on our email offers and newsletters.
How We Protect Your Information
We have put reasonable security measures in place to prevent the loss, misuse, destruction and alteration of information under our control. For example, when you access your account information, we use the Secure Socket Layer (SSL) protocol to encrypt information you input before it is sent to us.
Our Disclosure of Personal Information
Except as described in this Privacy Policy, we will not share your personal information with third parties unless you have consented to the disclosure or we believe the disclosure is appropriate to: (1) comply with the law or with legal process, (2) protect and defend our rights and property, such as to determine, bill and collect for amounts owed to us, (3) protect our customers or users, including from misuse or unauthorized use of the Sites or our services, or (4) protect the safety or property of our employees, customers, users or others. We may disclose or transfer your personal information (1) to our corporate affiliates (for example, subsidiaries or parent corporation), (2) to our service providers (like fulfillment, hosting, or payment service providers), but only for their use to provide the requested service to you, (3) to an acquirer in connection with the sale or other transfer of the business or assets of Glu, or (4) where you provide your express consent to the disclosure. We will require our corporate affiliates and service providers that receive your personal information to limit their use and disclosure of your information to the purposes for which you provided it.
We may employ third party companies and individuals to provide and/or facilitate our Services, to perform tasks, such as sending out newsletters and/or process billing transactions, or to assist us in analyzing how the Sites and Services are being used. These tasks necessarily require that we share your personal information with such third parties. We require that they adhere to this Privacy Policy and protect the confidentiality of your personal information, and they are prohibited from using your personal information for any other purposes without your consent.
Cookies
We use "cookies," which are small pieces of information that are stored by your browser on your computer's hard drive, and other technologies, to passively collect demographic information, personalize your experience on the Sites and monitor advertisements to track your purchases, the pages you have viewed, the games you have played and other activities. Our cookies do not contain any personally identifiable information and are used to either identify you as a returning customer or improve the experience on the Sites. Third parties that place advertising banners or other content on the Sites may also use cookies. Cookies received with ads collect information on behalf of the advertising companies, and we do not have access to this information. We are not responsible for the information collected by these third parties' cookies or the use by such third parties of the information they collect. Most browsers are set up to accept cookies, but you can adjust your browser settings to disable cookies or alert you when cookies are being delivered. Disabling cookies may prevent web sites from functioning as intended.
We may also maintain log files which contain IP addresses. An IP address is a numeric address that is assigned to your computer by your Internet Service Provider. In general, we only use log files to monitor traffic on the Sites, to report aggregate information to our advertisers and to troubleshoot technical problems. In the event of user abuse of the Sites, however, we may block certain IP addresses or console IDs provided by our licensed hardware manufacturers. IP addresses and console IDs may be used to personally identify you in order to enforce our Terms of Use.
A Special Note About Children
We urge parents to instruct their children to never give out their real names, addresses or phone numbers, without permission, when using the Internet. We recognize a special obligation to protect personal information obtained from young children. Therefore, with respect to children residing in certain jurisdictions, no information should be submitted by children 12 years of age or under. In order for children 12 years of age and under in such jurisdictions to participate in online activities that require registration, we require prior written permission or other verifiable consent from a parent or guardian. In other jurisdictions, prior written permission or other verifiable consent may be required from a parent or guardian for children 18 years of age and under. Upon registration, the appropriate permission form will be made available. This form must be signed by the child's parent or guardian and returned to Glu by mail to the Privacy Policy Administrator.
If for any reason you are concerned that your child's personally information maintained by us is not correct or complete, you wish to have your child's personal information deleted from our records, or you want us to discontinue further collection or use of your child's personal information, please contact our Privacy Policy Administrator who will be happy to review, update or remove your child's information as appropriate.
Where We Store Information
Glu is a global organization and many of the computer systems on which we collect, store and use the information we collect or receive are based in North America, Asia, Europe, Latin America and elsewhere. Your personal information may be transferred to, used, processed or held by us in these and in other countries, including countries both in and outside the European Union, and used for the purposes set out in this Privacy Policy.
Reviewing and Correcting Your Information, Requesting Removal from Mailing Lists and Deactivating Your Account
If for any reason you are concerned that the personal information maintained by Glu is not correct, or should you wish to have your account(s) deactivated or be removed from our mailing list, please email the Privacy Policy Administrator. We will be happy to review, update or remove information as appropriate. We may still retain your information in our files, however, to resolve disputes, enforce our user agreement, and due to technical and legal requirements and constraints related to the security, integrity and operation of the Sites.
By using the Sites, you signify your assent to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.
How to Contact Us
We welcome your questions and comments about privacy. Please send your feedback to our Privacy Policy Administrator.
