PRIVACY POLICY

The Happy Holodays Privacy Policy is designed to help you better understand the information we collect and the different ways we may use or share it. 

This policy applies to your use of the Popins services. By “Popins services,” we mean any of our websites, developer tools, applications, or other products or services that link to this policy. Additional terms and conditions may also apply to your relationship with Happy Holodays (“HH”), depending on how you choose to interact with us. Please read this entire policy to make sure you fully understand it. You should also be sure to carefully review other terms potentially applicable to your visit and your use of specific Popins services and confirm that you understand and agree to them, before using the Popins services.

Happy Holodays LLC and our subsidiaries operate and support the Popins services and is the controller of information collected under this policy.   

Please see “How to Contact Us” below to learn more about sending us any privacy-related questions or concerns you may have. 

 

Information We Collect

We generally collect information in three ways: (1) you voluntarily provide information to us, such as by signing up for email alerts, (2) we collect information automatically from your use of the Popins services, such as through cookies and our software, and (3) other parties, such as social networks, may provide information to us. Each of these methods is described in more detail below. 

(1) Information You Provide

You may provide your personal information to us when you choose to use the Popins services. Because we change our offerings and features from time to time, the options you have to provide us with information also may change. Some of the most common examples of situations in which you may provide information to us include:

  • Creating a Popins account;

  • Licensing and downloading our software;

  • Using social Popins services’ social features (see “When You Use Social Features of the Popins Services”);

  • Purchasing something from us or otherwise engaging in a transaction with us;

  • Entering online competitions or registering for or participating in special events;

  • Entering contests or sweepstakes, participating in any of our promotions, or accepting any prizes from us;

  • Signing up for email alerts or subscribing to receive other information from us;

  • Completing a survey;

  • Using a mobile device, such as a phone, to use our applications; and

  • Contacting us for any reason, such as by email, including for technical support or customer service.

The specific types of information you may be able to provide us will often vary depending on the Popins services you are using and how you interact with them. 

For example, you’d like to make a purchase, we may ask you to provide billing information (like your card’s payment account number and expiration date) to enable the transaction. Sometimes we ask for other information like your phone number, postal address, billing address, and date of birth. We’ll also collect information when you choose to share it with us directly in any other way, including by sending it as part of a communication with HH.

Some of our websites may provide a feature that supports job applications, in which case we also ask for your resume, real name, email address, and phone number. We use this information to determine if you are qualified for the position for which you applied or to contact you to set up an interview.

(2) Information We Collect Automatically

We collect some information automatically when you visit the Popins services. We typically aggregate this data and use it in statistical form to determine trends among groups of users, rather than using it to identify individuals.  If a combination of information that we collect does identify you as an individual, we will treat the combined information as personal information.

We collect information automatically through technologies such as web browsers, cookies, log files, web beacons, and our back-end servers collect usage data transmitted from the Popins services. We use the information for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud or misuse of our services, and conducting data analytics. The type of information that we automatically collect may vary, but generally includes:

  • Technical information about your computer, device, hardware, or software you use to access the Internet or our services, such as IP address or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system related specifications);

  • Usage information and statistics about your interaction with the Popins services, which may include the URLs of our websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, the application you used, how long you used it and when, and other usage statistics;

  • Crash reports, which may be automatically generated when an application crashes and includes information about your system and the crash;

  • Information that facilitates a safer and more personalized experience, such as your display name or other user identification provided in connection with your application use, saved preferences, progress, and device identifiers or usage information for authentication and fraud prevention purposes; and

  • The location of your device, such as may be derived from your device’s IP address.

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory. This Service does not use these “cookies” explicitly. However, the Popins service may use third party code and libraries that use “cookies” to collect information and improve the Popins service. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of the Popins service.

Please note that if certain features on the Popins services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the Popins services or others’ websites over time. These features are subject to those third parties’ privacy notices and policies. 

(3) Information We Receive from Others

In some cases, other parties provide us with information about you, or allow us to collect information about you. We generally collect information from other parties in four ways: (1) you interact with the Popins services using a service that is not controlled by us, such as a social network, (2) you choose to use a social feature of the Popins services, (3) you access Popins services through another party, such as a mobile device operator, or (4) you link a third party account to your Popins account. In some cases, we are not able to control the amount or type of information that other parties, like social networks, make available to us. In those cases, we use only the data that we need to provide the types of services we think our users want and expect. Although we cannot control your privacy settings at those websites or how those other parties protect your privacy, once we receive information about you through those websites, we will treat it in accordance with this policy.

 

When You Interact with the Popins Services on Third Party Services

When you interact with the Popins services on a website or app not controlled by us, that website or app may allow HH access to certain information about you. For example, social networks may provide us with information from your profile on their services or other information that you agreed the social network or other party could provide to us.

 

When You Use Social Features of the Popins Services

When you choose to use some of the Popins services’ social features, you allow us to receive information about you from third parties (like social networks). Our social features promote and facilitate interaction users. If you choose to use one of our social features, you may be asked to log into a social network through our application. The social network may then provide us with information such as your social network user ID, your profile picture, and the user IDs and profile pictures of your connections.

 

When You Access Popins Services through Other Parties or Devices

We may also receive information about you from the organizations that help enable your connection with the Popins services. Those parties may provide us with information regarding your account or registration, but they do not give us your payment information. Because those organizations determine what information they will collect from you, it may vary according to their services, but is likely to include details such as your display name and user ID for those services, as well as device and region information.

 

When You Link a Third Party Account to Your Popins Services

If you choose to link a third party account, such as a social media account, to your Popins services, the third party will provide us with information about that account. Because those organizations determine what information they will collect from you, it may vary according to their services, but is likely to include details such as your third party account display name and user ID, as well as associated device information, name, and email address.

 

How We Use and Share Information

As a general matter, we use and share the information we collect (either individually or in combination with other information collected as described in this policy) to help us provide, improve, customize, analyze, and market the Popins services where we have an appropriate basis to do so.

(1) Use

We rely on several different legal bases to process personal information for the purposes disclosed in this policy. These often depend on the exact nature of your relationship with us, but common examples include: 

  • To support our legitimate interests, such as:

·         To communicate with you, respond to your requests, or provide you with updates and information;

·         To better understand our users and their preferences;

·         To personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features;

·         To develop, deliver, and improve our products, services, and other offerings, some of which may be offered in partnership with other parties;

·         To manage and customize advertisements or promotional offers;

·         For security purposes; and

·         For internal purposes such as auditing and data analysis.

  • To provide services that are subject to terms you have accepted, such as enforcing our licenses, agreements, and terms of service, which may include reasonable monitoring to detect and prevent misuse or fraud, keep our games fair for all users, and otherwise protect and defend the Popins services. 

  • When you give consent, which you can withdraw at any time.

  • To comply with legal obligations.

We store personal information for as long as we reasonably need it to fulfill the purposes for which it was collected. 

(2) Sharing

Service Providers. We share personal information with service providers that we’ve engaged to help support the Popins services by performing certain services on our behalf and under our instructions. These service providers are not authorized by us to use or disclose personal information except as necessary to perform services on our behalf or comply with legal requirements.

Affiliates. We may share personal information we collect with affiliates of HH and/or the Popins services. 

Marketing Partners. We may share certain limited information, such as device identifiers, with marketing partners for purposes of executing and optimizing campaigns, and gauging the effectiveness of advertising and other marketing strategies solely on our behalf.

Social Features. We may share, or provide you with opportunities to share, information about you with other users of the Popins services. We also provide services that allow our users to communicate with each other, in which case personal information may be shared. For example, we may share information about you with your social contacts when you and they use the same social features of our applications.

We may also disclose information about you: (i) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iii) if necessary to protect the vital interests of another individual (such as to prevent death, bodily harm, or serious damage to property). We reserve the right to transfer information about our users in the event we sell or transfer all or substantially all our business or assets.

 

Your Choices and Controls

We seek to provide you with meaningful choices about the personal information you share with us, as well as the ways we may use or share that information. We’ll generally only ask you for personal information that is necessary to provide the Popins services you request. You can choose not to give us personal information we request, but if you decide not to, you may not be able to access certain parts of the Popins services and some features may not work as intended.

We may also seek your prior consent to process your information in certain ways. You aren’t required to provide consent if you do not want your personal information to be processed for the requested purposes, and may withdraw your consent at any time. Any withdrawal of consent is only effective on a going-forward basis and will not impact processing we undertook while relying on your consent.    

Other examples of your choices include:

  • You can browse our website without providing any personal information. We may collect some limited information automatically, as described above.

  • You may opt out of receiving our marketing messages at any time by using the opt-out mechanism provided in the message.

  • You can change your privacy settings on other parties’ websites, such as social networks, which will stop or limit our receipt of information from those other websites. You also may choose not to use social features we make available. If you choose to use these features, you should refrain from posting personal information that will be visible to others, such as including your email address in a forum or during a chat.

  • You may change your browser settings or take other steps to block, manage, or delete cookies. Not all of our websites and online services currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage cookies. In some cases, blocking or disabling cookies may cause our websites, games, and applications not to work as intended and some features may not be available.

  • You can limit interest-based advertising by opting out at www.aboutads.info/choices/ or www.networkadvertising.org/choices/. If you are located in Europe, more information is available at www.youronlinechoices.eu/.

  • If you are under the age of 18 and utilize the Popins services, you may ask us to assist you in addressing your privacy concerns by contacting us as described in the “How to Contact Us” section of this policy.

You may also exercise and amend your choices by sending an email to us as detailed in the “How to Contact Us” section below.

Sales of Information. We only uses the personal information we collect to help provide, support, and improve the Popins services as described in this policy, and we do not sell this information to third parties.  

 

How We Protect Information

We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature we offer, and in those cases you need to keep any user credentials and password confidential and secure so that your information is protected. 

 

Children’s Privacy

The Popins services are intended to be appropriate for general audiences and are not directed to children (usually considered to be under 13, depending on where you reside). We do not intentionally collect personal information from children without seeking any required parental approval in accordance with applicable legal and regulatory obligations, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”).

We may ask you to provide age-related information in order to help us comply with laws like COPPA. For example, we may request your date of birth to determine whether COPPA requires us to obtain verifiable parental consent from your parent or guardian before allowing you to access the Popins services.

If a user indicates they are a COPPA minor, we’ll require that user to complete a parental approval process before continuing to access the relevant Popins services. This process is designed to notify parents that their child has requested access to the Popins services, inform them about our privacy practices, offer them the opportunity to approve our collection and use of their child’s information as described in this policy, and describe the controls that we make available to them. 

Parents are also generally free to ask us any other questions you may have about how we handle your child’s personal information, please see “How to Contact Us” below.

Authorized child accounts are otherwise treated much like other Popins services accounts.

 

Transfers of Information

By using the Popins services, you acknowledge and agree that your information may be processed outside your country of residence, including in other jurisdictions that may have different data protection frameworks than your region.

 

Updates to Our Privacy Policy

This policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this policy when this policy was last updated. Please review this policy every time you access or use the Popins services to make sure that you have reviewed the most recent version.

 

How to Contact Us

If you have general questions or concerns about the Popins services, please contact our Support team at support@popins.io.

To learn more about our privacy practices or this policy, please email your questions to legal@popins.io.

Or contact us at Happy Holodays LLC, ATTN: Legal Department, 6505 Francis Ave N., Seattle, WA 98103, U.S.A.