PLAYNOMI PRIVACY POLICY


Effective 12/10/2012

Playnomi, Inc. (“Playnomi” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of our website, located at playnomi.com (the “Site”) and our applications for mobile devices (the “Applications”).   This Privacy Policy applies only to information that you provide to us through this Site and Applications.  This Privacy Policy may be updated from time to time.  We will notify you of any material changes by posting the new Privacy Policy on the Site or via the Applications.  You are advised to consult this policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Playnomi Terms of Use, accessible at playnomi.com/terms-of-service.html.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.  

Information Collection and Use

Our primary goals in collecting information are to provide and improve our Site, Applications, services, features and content, to administer use thereof (together, the “Service”) and to enable users to enjoy and easily navigate the Site and Applications.  

Personally Identifiable Information.  

o	When you register with us through the Service or when you choose to create your own optional User profile, we will ask you for personally identifiable information.  This refers to information about you that can be used to contact or identify you (“Personal Information”).  Personal Information includes, but is not limited to, your name, email address, phone number and SNS (defined below) profile picture, if such picture can be used to identify you.

o	You may register directly via the Service or by logging into your account with certain third party social media or social networking services (“SNS”) (including, but not limited to, Facebook) via the Services, as described herein.  If you decide to register through an SNS, we will extract the personal information you have provided to the SNS (such as your “real” name, email address and other information you make publicly available via the SNS) from the account you have with the applicable SNS and use that information to create your Account.  The specific information that we extract may depend on the privacy settings you have with the SNS.  You hereby consent to our access to and collection of such personal information about you.  

o	We also collect the other information that you provide as part of registration and the administration and personalization of your User profile (e.g., without limitation, city and state, gender and individual preferences) (“Non-Identifying Information”). From Users of the Applications only, we also collect mobile device identification information (UDID), Mac address and geolocation information. We will only collect such geolocation with your prior permission. 
o	We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service, complete your transactions, and administer your inquiries.   

o	Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified.  But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences).  We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Playnomi Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site, Applications and Service are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.

o	We also use your Personal Information to contact you with Playnomi newsletters, marketing or promotional materials and other information that may be of interest to you.  If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See “Changing or Deleting Information,” below.) 

Log Data.  When you visit the Service, whether as a registered User or a non-registered user just browsing (any of these, a “Playnomi User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”).  This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Service, pages of our Service that you visit, the time spent on those pages, information you search for on our Service, access times and dates, and other statistics.  We use Google Analytics to collect, monitor and analyze this information in order to increase our Service’s functionality and user-friendliness, and to better tailor it to our visitors’ needs.  Accordingly, Log Data is shared with Google, which has its own privacy policy addressing how it uses such information.   For example, some of this information is collected so that when you visit the Service again, it will recognize you and serve advertisements and other information appropriate to your interests.  We also use this information to verify that visitors to the Service meet the criteria required to process their requests.  We may use Log Data in association with Personal Information, and we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.

Cookies

Like many websites, we use “cookies” to collect information on the Site.  A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.  We utilize session ID cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by Playnomi Users and web traffic routing on the Site.  Session cookies are deleted from your computer when you log off from the Site and Service and then close your browser.  Third party advertisers on the Site may also place or read cookies on your browser.  You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.  If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Service. 

Phishing
Identity theft and the practice currently known as “phishing” are of great concern to Playnomi.  Safeguarding information to help protect you from identity theft is a top priority.  We do not and will not, at any time, request your credit card information, your Account login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.  For more information about phishing, visit the Federal Trade Commission’s website.

Inviting Friends to Use the Service

As part of the Service, Users may invite third party SNS friends or other friends who are not Users to use the Service through use of their Accounts.  Where you have selected the option to invite friends to use the Service, depending upon the selections you make via the Service, either (i) a message will be sent from your SNS account to the SNS account of the SNS friend(s) you select inviting such friend(s) to use the Service or (ii) we will send a one-time email to the friend’s email address you provide inviting them to join the Service. Your friend may request that we delete his or her email address from our records by contacting us at support@playnomi.com. 

Information Sharing and Disclosure

User Profiles.  When you register through the Service and submit your Personal Information to create a User profile, you will have the option to make such profile “public”, in which case it will be viewable publicly via the Service, or “private” in which case your profile will not be vieweable by other Users. You may provide information via your User profile such as your username, SNS profile picture or other profile picture, city, state, gender and Service-related preferences. We recommend that you guard your anonymity and sensitive information. 

Aggregate Information and Non-Identifying Information.  We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information. 

Service Providers.  We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site and Applications-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site’s and Applications’ features) or to assist us in analyzing how our Site, Applications and Service are used.  These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. 

Compliance with Laws and Law Enforcement.  Playnomi cooperates with government and law enforcement officials and private parties to enforce and comply with the law.  We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Playnomi or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity. 

Business Transfers.  Playnomi may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.  

Changing or Deleting Your Information

All Users may review, update, correct or delete the Personal Information in their Accounts by contacting us.  If you completely delete all such information, then your Account may become deactivated.  If you would like us to delete your Account in our system, please contact us at support@playnomi.com with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request.  We may retain an archived copy of your records as required by law or for legitimate business purposes.

Security 

Playnomi is very concerned with safeguarding your information.  The security of your personal information is important to us.  But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure.  When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).  In some cases, we also encrypt sensitive information where it is stored on our systems.

We will make any legally required disclosures of any  breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site or via the Applications in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

International Transfer

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside the United States and choose to provide information to us, Playnomi transfers Personal Information to the United States and processes it there.  Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Sites

Our Service contains links to other websites.  If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website.  The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.  We do not exercise control over third party websites.  These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you.  Other sites follow different rules regarding the use or disclosure of the personal information you submit to them.  We encourage you to read the privacy policies or statements of the other websites you visit.  

Our Policy Toward Children

The Service is not directed to persons under 13.  We do not knowingly collect personally identifiable information from children under 13.   If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at  support@playnomi.com  If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.  

Contacting Us 

If you have any questions about this Privacy Policy, please contact us at legal@playnomi.com or at: 1849 Church Street, #3, San Francisco, CA 94131