Privacy Policy (20190709)

Game Circus Privacy Policy

Effective Date: July 9, 2019

By installing and launching Game Circus mobile applications or games, you agree and consent to all terms and conditions specified in this Privacy Policy.

This Privacy Policy explains how information about you is collected, used, and disclosed by Game Circus LLC and any parent or subsidiary (collectively, “Game Circus,” “our”, “us” or “we”) when you access or use Game Circus websites, mobile applications, and other products and services (collectively, the “Services”) or otherwise interact with us.  This policy applies to Game Circus brands, websites, games, applications, and other technologies (we collectively refer to these as “Services”).

Advertising is a core part of Game Circus business. Many of our free mobile games, mobile applications and technologies are supported by the ads we and others display. We provide a variety of online advertising services to other companies that want to place ads on our Services.  We display ads, also known as graphical ads, which appear as images, animation, or video. Game Circus advertising platforms provide the means for advertisers, agencies, publishers, and ad networks to manage their advertising business. Advertising networks may collect and use data they receive about you to help show ads for products or services that you are more likely to be interested in to make the advertising more useful and effective. By installing and launching our games you understand and consent to our use of data as defined in our Policy Policy.

Our Privacy Pledge

Our commitment is to put users first. We strive to be transparent about how we collect and use information from our users, to keep the information we collect secure, and to provide users meaningful choices. Since our founding in 2010, Game Circus has intentionally avoided collecting data that identifies specific individuals (such as name, email address, physical address, GPS or phone number) to the extent possible.  Game Circus has appointed a Data Protection Officer to ensure Game Circus maintains safe and consistent practices regarding your data and privacy.

Collection of Information

We collect the following types of information when you interact with our Services:

  • Device Identifiers.  When you interact with our Services, we do not require you to provide information that identifies you personally.  Instead, we collect and identify your device primarily using your mobile device advertising identifier, e.g. Apple’s iOS Identifier for Advertising (IDFA) or Google’s Android Advertising ID, as well as other identifiers.
  • User Names. If you would like to participate in our leaderboards, keep track of your game progress or play our multiplayer games, we may ask you to provide a username. To help protect your privacy, please do not choose a username which could be used to personally identify you, e.g. “JimSmith” or “Jsmith”.
  • Other Information You Provide to Us.  We collect the information that you provide to us, for example when you communicate with others or post, use messenger or chat services, upload or store content, contact our Technical Support team, or provide billing information.
  • Taxpayer Information. We may require players (US Citizens and Residents) to complete an online US IRS Form W-9 (Request for Taxpayer Information) if a player wins a prize in one of our online Sweepstakes. Sweepstakes are limited to US Citizens and Residents and WINNERS ARE SOLELY RESPONSIBLE FOR ALL FEDERAL, STATE AND LOCAL TAXES ASSOCIATED WITH THE RECEIPT OR USE OF ANY PRIZE. The W-9 will be used by Game Circus to generate, mail and file IRS Form 1099-MISC to both the player and the US Internal Revenue Service. Please note that it is a crime for US Citizens and Residents to provide false, incorrect or misleading information on an IRS Form W-9.
  • Log Information. We automatically collect information about your use of our Services and your device, including your IP Address, device model, browser version, operating system type, operating system version, mobile network information, device settings, and software data.
  • Location Information.  We derive information about your general location (city, country) from your IP Address.  Game Circus does not collect precise location data, such as GPS coordinates, that could be used to pinpoint your physical location.
  • Information from Cookies and Other Technologies. We collect information using web beacons, cookies, and similar technologies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, count visits, and understand how users interact with ads.  Web beacons are electronic images that may be used in our Services and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see “Your Choices” below.
  • Information from Others.  We collect information about you when we receive it from other users, third parties, and affiliates. For example, when you connect your account to third-party services or sign in using a third-party partner (like Google Play Game Services, iOS Game Center or Facebook), we collect information in accordance with the privacy policies and authorization procedures determined by those services.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Game Circus and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For a full list of the companies we partner with to show you interest-based ads, please visit www.gamecircus.com/third-parties. For more information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for interest-based advertising purposes.

Use of Information

We use the information we collect to deliver, personalize, and improve our Services. We also use the information we collect to:

  • Personalize the Services and provide advertisements, content, or features that are targeted toward your interests;
  • Save and associate your activity across our Services and your different devices as well as associate any accounts you may use across Game Circus Services together. We may associate activity and accounts under a single user ID;
  • Carry out or support promotions;
  • Create analytics and reports for external parties, including partners, publishers, advertisers, apps, third-parties and the public regarding the use of and trends within our Services and ads, including showing trends to partners regarding general preferences, the effectiveness of ads and information on user experiences; and
  • Detect and defend against fraudulent, abusive, or unlawful activity

Sharing of Information

We share the information we collect within the Game Circus family of brands. We do NOT sell, license or share information that individually identifies our users with companies, organizations or individuals outside of Game Circus unless one of the following circumstances applies:

  • With Affiliated Brands. Game Circus shares information within its affiliated brands.
  • With Your Consent. We will share information with companies, organizations or individuals outside of Game Circus when we have your consent to do so.
  • With Service Providers. We provide user information to trusted partners who work on our behalf based on our instructions and in compliance with appropriate confidentiality measures.
  • For Legal and Other Purposes. We may access, preserve, and disclose information to investigate, prevent, or take action in connection with: (i) legal process and legal requests; (ii) enforcement of our Terms of Service; (iii) claims that any content violates the rights of third parties; (iv) protecting the rights, property or personal safety of Game Circus, its users, or the public; (v) establishing or exercising our legal rights or defending against legal claims; or (vi) as otherwise required by law.
  • New Ownership. If the ownership or control of all or part of Game Circus or specific Services changes as a result of a merger, acquisition or sale of assets, we may transfer your information to the new owner.

Your Choices

  • Accounts. In most cases, you can easily delete your data at any time by deleting the app and/or resetting your Advertiser ID. We can no longer associate any stored data with you. If you have linked a social account (e.g. FaceBook, GPGS or GameCenter), then you can unlink the app with those social providers to disassociate yourself with any stored data. If you do this, your unique username and gameplay may no longer be retrievable. If you have any further questions regarding remove of data, please contact support@gamecircus.com.
  • Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies; however, the Services may not function properly if you do so.
  • Notifications. You have the ability to turn application notifications on and off by adjusting the settings of your mobile device. If you wish to allow or discontinue receiving Push Notifications or Local Notification, please consult the settings on your mobile device.

Information Security

Game Circus has adopted commercially reasonable technical, administrative and physical safeguards in place to help protect against unauthorized access, use or disclosure of customer information we collect or store.

Data Retention

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

Protecting Children’s Privacy

Our Services are not intended for use by children. We do not knowingly collect, use, or share information from children under age 16. If you believe that your child may have provided us with personal information, please contact us at support@gamecircus.com

Data Transfers

Game Circus is based in the United States and we process and store information in the U.S. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

Residents of the European Economic Area

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

  • Legal Basis for Processing. If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:
    • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments and providing the services you have requested).
    • We have a legitimate interest in processing your personal data. For example, we may process your personal data to keep track of your gameplay.  If you win one of our sweepstakes (open to residents and citizens of the US), you may be required to fill out an IRS W-9 (Request for Taxpayer Information) so we can send you a 1099-MISC and correctly report winnings to the Internal Revenue Service.
    • We have your consent to do so. For example, we may seek your consent to show you interest-based ads.
  • Data Subject Requests. If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to withdraw a consent you previously provided, or to object to or request that we restrict certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.
  • Questions or Complaints. If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see:

Changes to the Privacy Policy

Game Circus may change this Privacy Policy at any time. If we make a change, we will notify you by revising the “Effective Date” date above and, in some cases, we may provide you with more prominent notice. We encourage you to review this Privacy Policy frequently to stay informed about our information practices and your privacy choices.

Contact Information

If you have questions, suggestions, or wish to make a complaint, please complete a feedback form or you can contact us at:

Game Circus, LLC
15851 Dallas Parkway, Suite 475
Addison, TX 75001-6327

General questions: support@gamecircus.com
GDPR specific questions: gdpr@gamecircus.com

Links to Previous Privacy Policies

These links are provided for historical reference.  Please note that the current July 2019 Privacy Policy replaces all existing policies.