Supplemental California Consumer Privacy Act Disclosures

Last Updated: January 1, 2020

In these Supplemental California Consumer Privacy Act Disclosures (“CCPA Disclosures”), we, Glu Mobile Inc., disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”) and supplement the disclosures in our Privacy Policy at www.Glu.com/privacy/. We use the term “Services” to mean our websites, mobile applications and other online products and services.

These CCPA Disclosures are effective January 1, 2020.

I.  Who and what information is subject to these CCPA Disclosures?

California residents are protected as “consumers” by the CCPA with respect to their personal information.

A number of statutory exceptions apply under the CCPA and to these CCPA Disclosures, including the following:

(1) personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency;

(2) personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business;

(3) personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; and

(4) personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.

 

II.  How can a consumer with a disability access these CCPA Disclosures?

Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this notice.

III.  CCPA Notice at Collection Online

In this CCPA Notice at Collection Online, we are addressing disclosure requirements under California Civil Code § 1798.100(b) and California Attorney General Regulations § 999.305 at or before the point of online collection:

We collect the following categories of personal information about consumers:

  • Information you provide directly to us. For example, we collect information when you create an account, manage your user profile, participate in any interactive features of the Services, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The types of information we collect may include your name, email address, postal address, photograph, avatar, password, phone number, username, gender, birth day, forum posts and comments, messages between users and other contact or identifying information you choose to provide, but, as you’ll see when you interact with our Services, the exact types of information we collect will depend on the Service you choose to use.Prize winners of contests or sweepstakes may also have to provide their Social Security Numbers, which are used exclusively for prize fulfillment and related tax purposes. We use this information in order to respond to your requests, answer your questions or provide our Services to you.
  • Information automatically collected.When you access or use our Services, we automatically collect information about you, including:
    • Device Information: We collect device-specific information when you access our Services from a mobile device, including your hardware model, operating system and version, unique device identifiers, mobile network information and country, language, screen size and resolution, and battery life remaining.
    • Use Information: We collect information about your use of the Services, including the type of browser you use, access times, pages viewed, game play activity, interactions with other players, your IP address and, with respect to our website, the page you visited before navigating to our Services.
    • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this includes sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below. We also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that are used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
    • Other Information Collected with Permission:Our mobile applications that are distributed through various “app” stores also request permission to automatically collect other information from your mobile device, including your email address. We only collect this information with your authorization in accordance with your device operating system’s permission process.
    • Social Media Information:We also obtain information from other sources and combine that with information we collect through our Services. For example, if you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information, profile picture, phone number, email address, gender, date of birth and friends lists, in accordance with the authorization procedures determined by such social media site.

We use this information to provide, maintain, secure, customize and improve our Services; setup your gWallet account and manage the Glu credits that you earn and use across our Services; provide and deliver the products and services you request and send you related information, including confirmations and invoices; send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you; send you technical notices, updates, security alerts and support and administrative messages; monitor and analyze trends, usage and activities in connection with our Services; personalize and improve the Services and provide advertisements, content, suggested connections or features that match user profiles or activities; process and deliver contest entries and rewards; and carry out any other purpose for which you consent at the time of collection.

IV.  CCPA Privacy Policy

Beyond the disclosures in the preceding “CCPA Notice At Collection Online” section, we are providing additional disclosures about consumer rights and our personal information handling practices in the preceding twelve months, as required by the CCPA and regulations of the California Attorney General, including § 999.308 (Privacy Policy).

1.     Right to Know About Personal Information Collected, Disclosed, or Sold

This Supplemental CCPA Privacy Policy describes the personal information we generally collect, use, disclose and sell about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please submit an email request to support@glu.comand include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

2.     Our Personal Information Handling Practices in 2019

We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.

 

Category of personal information We collected such personal information to use for the following business or commercial purposes: We have collected such personal information from the following categories of sources: We shared such personal information with the following categories of third parties:
1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

Any categories of personal information described in subdivision (e) of Section 1798.80: “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, telephone number, education, employment, or medical information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.

Electronic Information.

We use this information to provide, maintain, customize and improve our services; setup your gWallet account and manage the Glu credits that you earn and use across our services; provide and deliver the products and services you request and send you related information, including confirmations and invoices; send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you; send you technical notices, updates, security alerts and support and administrative messages; monitor and analyze trends, usage and activities in connection with our services; personalize and improve the services and provide advertisements, content, suggested connections or features that match user profiles or activities; process and deliver contest entries and rewards; and carry out any other purpose for which you consent at the time of collection. Directly from the California resident, Social Media Sites and service providers. ·     With vendors, consultants and other service providers who need access to such information to provide services to us or to you;

·     With other users of the social features of the Services. For example, your username, profile picture and the virtual content you have accumulated in a game may be visible to other users of that game. Additionally, information that you provide in your account registration for a forum and your forum comments may be available to other forum users.

·     In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;

·     If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Glu or others;

·     In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or

·     With your consent or at your direction.

·     We also share aggregated or de-identified information, which cannot reasonably be used to identify you.

2. Characteristics of protected classifications under California or federal law, including  age (40 years or older), race, color, national origin, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), and sexual orientation.

Biometric information.

 

 

We use this information to provide, maintain, customize and improve our services; send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you; monitor and analyze trends, usage and activities in connection with our services; personalize and improve the services and provide advertisements, content, suggested connections or features that match user profiles or activities; process and deliver contest entries and rewards; and carry out any other purpose for which you consent at the time of collection. Directly from the California resident

 

For the purposes identified above, with vendors, consultants, other service providers; in response to a request for information; in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or with your consent or at your direction.
3. Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We use this information to provide, maintain, customize and improve our services; setup your gWallet account and manage the Glu credits that you earn and use across our services; provide and deliver the products and services you request and send you related information, including confirmations and invoices; send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you; send you technical notices, updates, security alerts and support and administrative messages; monitor and analyze trends, usage and activities in connection with our services; personalize and improve the services and provide advertisements, content, suggested connections or features that match user profiles or activities; process and deliver contest entries and rewards; and carry out any other purpose for which you consent at the time of collection. Directly from the California resident

 

For the purposes identified above, with vendors, consultants, other service providers; in response to a request for information; in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or with your consent or at your direction.

 

4. Internet or other electronic network activity information, including, but not limited to, and information regarding a consumer’s interaction with an Internet Web site. We use this information to provide and improve our services; provide and deliver the products and services you request and send you related information, including confirmations; send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you; send you technical notices, updates, security alerts and support and administrative messages; monitor and analyze trends, usage and activities in connection with our services;process and deliver contest entries and rewards; and carry out any other purpose for which you consent at the time of collection. Directly from the California resident.

 

·     With vendors, consultants and other service providers who need access to such information to provide services to us or to you;

·     In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;

·     If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Glu or others;

·     In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or

·     With your consent or at your direction.

·     We also share aggregated or de-identified information, which cannot reasonably be used to identify you.

5. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We use this information to provide, maintain, customize and improve our services; send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you; monitor and analyze trends, usage and activities in connection with our services; personalize and improve the services and provide advertisements, content, suggested connections or features that match user profiles or activities; and carry out any other purpose for which you consent at the time of collection. Directly from the California resident, Social Media Sites and service providers. For the purposes identified above, with vendors, consultants, other service providers; in response to a request for information; in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or with your consent or at your direction.

 

3.     Disclosures of Personal Information

Over the preceding 12 months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in the table above. We did not “sell” personal information in the preceding 12 months, as the term “sell” is defined in the CCPA. However, as mentioned in our Privacy Policy, we allow certain business partners to receive your information in connection with providing services to you or to us .  If you would like to opt-out of this practice, please see the “Your Choices” section in our Privacy Policy. If a consumer clicks on ads shown on our services, downloads apps, or otherwise engages with third parties, the consumer sends their personal information to third parties. Glu Mobile does not control the data processing practices of third-party advertisers and recommends that consumers review the advertisers’ privacy policies before sending personal information to them.

4.     Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to support@glu.comand include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted.

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

 

5.     Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your personal information by a business. We did not “sell” personal information in the preceding 12 months, as the term “sell” is defined in Cal. Civ. Code § 1798.140(t)(1).

6.     Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code § 1798.125.

7.     Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf if:

  • The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
  • You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 2 and 3 above:

  • Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to Glu Mobile Inc., Attn.: Customer Care, 875 Howard Street, Suite 100, San Francisco, CA 941003, support@glu.com; and
  • Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

8.     Contact for More Information

If you have questions or concerns regarding our privacy policy or practices, you may contact us using the following details:

Email address: privacy@glu.com

Postal address: Privacy Policy Administrator, Glu Mobile Inc., 875 Howard Street, Suite 100, San Francisco, CA 94103