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New Hill Strategic Management Ltd. Privacy Policy is designed to provide clarity about the information we collect and how we use it to provide a better social networking experience. By accepting our Privacy Policy and Terms of Use in registration or application installation, you consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.
New Hill Strategic Management Ltd. develops and publishes social applications. In this policy, “New Hill Strategic Management Ltd.” refers to New Hill Strategic Management Ltd. and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We may also refer to New Hill Strategic Management Ltd. as “We” or “Us”. This Privacy Policy describes: the information we collect, how we do so and the purposes of our collection how we use and with whom we share such information how you can access and update such information the choices you can make about how we collect, use and share your information how we protect the information we store about you If you have questions regarding this Privacy Policy or our collection and use of information, please contact us as described in Section 14 (“Contact Us”). If you access our applications from a third party Social Networking Site (“SNS”), you may be required to also read and accept the SNS Terms of Use and Privacy Policy.
When you use any New Hill Strategic Management Ltd. application at an SNS such as Facebook or MySpace, you allow New Hill Strategic Management Ltd. to access certain information from your profile for that site. The information you allow New Hill Strategic Management Ltd. to access varies by application and SNS platform, and it is affected by the privacy settings you establish at the SNS. You can control and find out more about these settings at the SNS where you use our applications. For example, New Hill Strategic Management Ltd. may access and store some or all of the following information, as allowed by you, the SNS and your preferences:
By using an New Hill Strategic Management Ltd. application through an SNS, you are authorizing New Hill Strategic Management Ltd. to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the SNS could provide to New Hill Strategic Management Ltd. through the SNS Application Programming Interface (“API”). Your agreement takes place when you “accept” or “allow” (or similar terms) one of our applications on an SNS.
When you interact with New Hill Strategic Management Ltd. directly, either through a New Hill Strategic Management Ltd. application (whether or not on an SNS), at new-hill.co.uk, or any New Hill Strategic Management Ltd.-owned website, we may collect and store information from you directly as described below:
When you register with us directly, you will be required to provide at least the following information:
We may also offer you the option to complete a user profile that is visible to other New Hill Strategic Management Ltd. users. Your user profile may include:
The New Hill Strategic Management Ltd. user ID number used to identify your account and profile will be public and will appear in the URL of your profile page, but will only permit access to information that is considered public or that you have designated as public in your settings.
Your first and last names and profile picture are considered “public” on New Hill Strategic Management Ltd. websites that offer direct access to New Hill Strategic Management Ltd. applications and search engines may index this publicly available information. When we offer profiles, we will also offer functionality that allows you to opt-out of public indexing of your public profile information.
We will also offer you the ability to import your address book contacts or manually enter email addresses so that you can (i) locate your contacts on New Hill Strategic Management Ltd.; and (ii) invite those contacts to join you in our applications. We will store those contacts for purposes of helping you and your contacts make connections on our site. If you do not want your contacts stored just follow the instructions available at the “Learn More” link. Passwords provided to New Hill Strategic Management Ltd. for the purpose of accessing your address book will not be stored.
If you use New Hill Strategic Management Ltd. applications on your mobile telephone or other mobile device, we collect your unique device identifier and may collect your telephone number, country, and other information you choose to provide, such as user name, character name, location or e-mail address (i.e., to receive updates about the application).
If you purchase in-application virtual currency or goods from New Hill Strategic Management Ltd., we will collect the billing and financial information necessary to process your charges, including your postal and e-mail addresses, depending on your payment method. New Hill Strategic Management Ltd. may also receive the billing and payment information that you provide when you purchase New Hill Strategic Management Ltd. virtual goods or currency via a mobile device, such as an iPhone. We use and store this data in the same manner as billing and payment data collected from non-mobile visitors to our applications. Our Terms of Use explain our policies and terms relevant to our charges and billing practices. Please note that purchases of Facebook Credits are subject to Facebook policies.
When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your application use or activity on the Service, and your user ID number. We will also store the correspondence and any information contained within.
We receive and store the information you provide, such as a user ID number or valid e-mail address or street address, when you enter any New Hill Strategic Management Ltd. application promotion, sweepstakes or loyalty program. Promotions which offer prizes (for example, other than virtual currency or virtual goods) will have separate requirements for eligibility and other rules, which you can easily locate and should review before deciding whether to participate.
We receive and store the information you provide, including your telephone number, when you sign up to have SMS notifications sent directly to your mobile phone. These messages notify you of in-application activity and may allow you to use the application from your phone. You can adjust the types of notifications you receive and when you receive them by editing your SMS notification settings; just log in to your application account and choose SMS mobile from the Help menu.
When you access our websites or use our applications, we collect (i) certain technical information about your computer system and (ii) usage statistics about your interactions with our websites and applications. This information is collected through the use of server log files and tracking technologies to collect and analyze certain types of technical information including cookies. Some of the cookies the Service places on your computer are linked to your user ID number(s). For more information on how we utilize cookies and other tracking technologies please review the “Cookies and Automated Information Collection” portion of Section 3 (“How We Collect Information about You”).
Users may have the opportunity to download and install a New Hill Strategic Management Ltd. branded toolbar (the “Toolbar”) when using various applications. This Toolbar allows you to monitor your real time status for New Hill Strategic Management Ltd. applications while you are browsing non-New Hill Strategic Management Ltd. websites. As the Toolbar is improved, it will be automatically updated on your browser. The Toolbar itself does not collect personal information. However, there are some features within the Toolbar that may allow you to provide personal information (e.g. Contact form, Tell-a-friend). Additionally, we may keep statistics regarding toolbar use on an aggregated basis. The Toolbar is based on technology provided by Conduit, whose privacy policy is available here.
We may collect information about you in any one or more of the following ways:
When you use one of our applications, New Hill Strategic Management Ltd. collects and stores certain profile information that you provide directly or through the SNS or other third party website that is offering our applications(s). To provide a richer application and social networking experience, we also collect information about your usage and interaction with other users and the Service. The bulk of this information is collected and stored through the use of web logs, which are files on our web servers that record actions taken on our applications and websites.
You may be able to take part in certain activities on our websites or applications that give you the opportunity to communicate or share information not just with New Hill Strategic Management Ltd., but also with other users of our Service. These include:
We may record and store archives of these communications on New Hill Strategic Management Ltd.’s servers to protect the safety and well being of our users and New Hill Strategic Management Ltd.’s rights and property in connection with the service You acknowledge and consent to the recording and storage of such communications for these purposes.
When you access our websites or use our applications, we collect certain technical information in order to (i) analyze the usage of our sites and services which allows us to improve the service, (ii) provide a more personalized experience and (iii) manage advertising. We and service providers acting on our behalf, such as Google Analytics, use server log files and tracking technologies to collect and analyze certain types of technical information, including cookies, IP addresses, browser types, browser language, referring and exit pages, and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, application state and the date and time of activity on our websites or applications, and other similar information. In some cases, we will associate this information with your user ID number for our internal use. We may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation; (iii) local shared objects also known as flash cookies, which help us to prevent fraud, remember your in-application settings for features like music and to track your progress on certain in-application features. You can set your web browser to warn you about attempts to place cookies on your computer, or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser will not remove flash cookies. To learn more about and manage flash cookies you can visit adobe.com and make changes at the privacy settings panel. If you disable cookies, you may lose some of the features and functionality of using our applications, as New Hill Strategic Management Ltd. cookies are necessary to track and enhance your application activities. Please note that companies delivering advertisements in our applications or on our websites may also use cookies or other technologies, and those practices are subject to their own policies.
We may collect or receive information from other sources including (i) other New Hill Strategic Management Ltd. users who choose to upload their email contacts, and (ii) third party information providers. This information will be used to supplement your profile – primarily to help you and your friends connect. It will be combined with other information we collect.
In general, we collect, store and use your information to provide youwith a safe, smooth, efficient, and customized experience. Forexample, we may use information collected from you in any one or moreof the following ways:
One important use of your information is communication. If you haveprovided your email address to New Hill Strategic Management Ltd.,we’ll use it to respond to (i) customer support inquiries, and (ii)keep you informed of your in-application activity, including commentsfrom friends and notifications about in-application. We may also sendpromotional e-mail messages and promotional SMS messages (“PromotionalCommunications”) directly or in partnership with parties other thanNew Hill Strategic Management Ltd..
You always have the choice to stop receiving PromotionalCommunications. When you receive Promotional Communications from usyou will have the opportunity to “opt out” by (i) following theunsubscribe instructions provided in the Promotional Communication youreceive or (ii) by editing your preferences. Please note that despiteyour indicated e-mail preferences, we may still send youadministrative messages regarding New Hill Strategic Management Ltd.applications, including, for example, administrative confirmations,and notices of updates to our Policies. For more information on yourmessaging options see “Your Sharing and Messaging Options” below.
We will share your information (in some cases personal information)with third parties, that is parties other than New Hill StrategicManagement Ltd., in the following circumstances:
We will provide your information to third party companies to performservices on our behalf, including payment processing, data analysis,e-mail delivery, hosting services, customer service and to assist usin our marketing efforts. We direct all such third party serviceproviders to maintain the confidentiality of the information disclosedto them and to not use your information for any purpose other than toprovide services on New Hill Strategic Management Ltd.’s behalf.
In some New Hill Strategic Management Ltd. applications other userswill be able to see your application name or pseudonym and aapplication profile. Your application profile may include your profilephoto, which in certain cases can reveal your User ID number. Accessto this information may allow others to view the public informationassociated with your related SNS account.
We do not actively share personal information with third partyadvertisers for their direct marketing purposes unless you give usyour consent. If we wish to share in this fashion, we will ask foryour consent. Advertisers, however, may obtain public informationabout you from your profile or other public sources. We may use andshare with third parties certain technical information (including IPaddresses) or aggregated information to show general demographic andpreference information among New Hill Strategic Management Ltd. users.We may also allow advertisers to collect technical or aggregatedinformation, which they may share with us, with tracking technologieslike cookies and web beacons. The information collected may be used tooffer you targeted ad-selection and delivery in order to personalizeyour user experience by ensuring that advertisements for products andservices you see will appeal to you, a practice known as behavioraladvertising, and to undertake web analytics (i.e. to analyze trafficand other end user activity to improve your experience). To learn moreabout behavioral advertising or to opt-out of this type of advertisingfor participating ad networks, you can visit the Network AdvertisingInitiative website. Our collection, use, and disclosure of anonymousand aggregated information are not subject to any of the restrictionsin this Privacy Policy.
New Hill Strategic Management Ltd. applications or their purchasepages may disuse an “offer wall” that is hosted by an offer wallprovider. The offer wall allows third party advertisers to providevirtual currency to users in exchange for interacting with anadvertisement or for completing a marketing offer that may includesigning up for an account with one of those advertisers. These are notoffers made by New Hill Strategic Management Ltd.. These offers may bedisplayed to you based on certain technical information, such as yourgeographic area or anonymous demographic information. After clickingon one of these advertisements, you will no longer be on a site hostedby New Hill Strategic Management Ltd. or partnering SNS. To properlycredit user accounts and to prevent fraud, a unique identifier, insome cases your user ID number, will be shared with the offer wallprovider. This identifier is used to ensure proper crediting of youraccount, prevent fraud or duplicate offers and to resolve any customerservice inquiries that may arise. Once you complete an offer, you willthen return to a New Hill Strategic Management Ltd. website orapplication.
Your information, and the contents of your private onlinecommunications, may be accessed and disclosed (i) in response to legalprocess (for example, a court order, search warrant or subpoena); (ii)when we have a good faith belief that we are required to disclose theinformation in response to legal process; (iii) in other circumstancesin which New Hill Strategic Management Ltd. believes the New HillStrategic Management Ltd. applications or web sites are being used inthe commission of a crime (including exchanging information with othercompanies and organizations for the purposes of fraud protection andcredit risk reduction); (iv) when we have a good faith belief thatthere is an emergency that poses a threat to the safety of you oranother person; and (v) when necessary either to protect the rights orproperty of New Hill Strategic Management Ltd. including to enforceour Terms of Use, or for us to render the service you have requested.
In the event that New Hill Strategic Management Ltd. undergoes abusiness transition, such as a merger, acquisition by another company,or sale of all or a portion of its assets, we may transfer all of yourinformation, including personal information, to the successororganization in such transition. If material changes to New HillStrategic Management Ltd.’s privacy practices will occur as a resultof the business transition, we will notify you and other users (in themanner described in Section 12) of the business transition prior totransferring your personal information.
Our websites and applications are not intended for children under theage of 13 and we do not knowingly collect any personal informationfrom such children. Children under the age of 13 should not use ourwebsites or applications at any time. In the event that we learn thatwe have inadvertently gathered personal information from childrenunder the age of 13, we will take reasonable measures to promptlyerase such information from our records.
To manage the information New Hill Strategic Management Ltd. receivesabout you from the SNS where you use our applications, you will needto follow the instructions at that site for updating your informationand changing your privacy settings. On Facebook, for example, as ofthe effective date of this Privacy Policy, you can edit your privacysettings for applications to do the following:
Once New Hill Strategic Management Ltd. receives your information froman SNS, that information is stored and used by New Hill StrategicManagement Ltd. in accordance with this Privacy Policy, and you mayaccess and update that information as described below.
If you use our applications at a third-party SNS, New Hill StrategicManagement Ltd. will be able to access and store profile and otherinformation about you as described above. The categories ofinformation you share with us will depend, in part, on the privacysettings you have established at the SNS where you access theapplication. Many SNS allow you to control how you share informationwith third-party applications and websites, such as New Hill StrategicManagement Ltd. applications, through your privacy settings on eachSNS. New Hill Strategic Management Ltd. does not control what privacysettings those sites make available to their users, so we refer you tothe privacy policies that are posted on those sites to learn whatoptions they make available to their users. New Hill StrategicManagement Ltd. does not offer an “opt out” option for specific fieldsthat are shared by the SNS where you access and use theapplication(s).
You can choose to opt out of receiving additional promotional e-mailsfrom New Hill Strategic Management Ltd. by clicking on the”unsubscribe” link in any such e-mail. Please note that once wereceive your request, it may take an additional period of time foryour opt-out to become effective. Your unsubscribe or e-mailpreference change will be processed promptly, and in no event longerthan 10 business days. You can opt out of receiving SMS messages bytexting STOP to the number we send from for that particular SMSprogram. In some cases a preference management page will also beavailable under the “Help” menu of the application that is offeringthe SMS program. When you install our apps on your mobile device youcan choose to receive push notifications. These notifications can beturned off by modifying your mobile device settings for notifications.Note that if you opt-out of our Promotional Communications, we maystill e-mail or communicate with you from time to time if we need toprovide you with information or if we need to request information fromyou with respect to a transaction initiated by you or for otherlegitimate non-marketing reasons.
As part of our international operations, we may transfer data to ourAffiliates from time to time for our legitimate business purposes. Forexample, New Hill Strategic Management Ltd. provides certain servicesto its Affiliates (which shall mean subsidiaries, parent companies,joint ventures and other corporate entities under common ownership).New Hill Strategic Management Ltd. stores information about sitevisitors and users on servers located in the United States, and NewHill Strategic Management Ltd. may also store such information onservers and equipment in other countries. Personal data collectedwithin Switzerland and the European Economic Area (“EEA”) may betransferred to, and stored at, a destination outside of Switzerlandand the European Economic Area (“EEA”). The data we hold may also beprocessed by employees operating outside of Switzerland and the EEAwho work for us or one of our Affiliates or for one of our vendors.Such staff may be engaged in, among other things, (i) the processingof transactions and your payment details and (ii) the provision ofsupport services. By submitting your personal data or using New HillStrategic Management Ltd. applications, you agree to this transfer,storing or processing. New Hill Strategic Management Ltd. complieswith the Safe Harbor framework as set forth by the Department ofCommerce regarding the collection, use, and retention of online userdata from the European Union and Switzerland. We will take all stepsreasonably necessary to ensure that your data is treated securely andin accordance with this privacy policy.
Our websites and applications may contain advertisements fromcompanies other than New Hill Strategic Management Ltd. with their ownwebsites. We are not responsible for the privacy practices or thecontent of such websites. If you have any questions about how theseother websites use your information, you should review their policiesand contact them directly.
New Hill Strategic Management Ltd. implements reasonable securitymeasures to protect the security of your information both online andoffline, and we are committed to the protection of customerinformation. For user accounts registered directly with New HillStrategic Management Ltd. profile information is protected by thepassword each member uses to access their online account. It isimportant that you protect and maintain the security of your accountand that you immediately notify us of any unauthorized use of youraccount. If you forget the password to your New Hill StrategicManagement Ltd. account, the website allows you to request thatinstructions be sent to you that explain how to reset your password.When you sign into your account or enter payment information (such asa credit card number when purchasing virtual currency), we encrypt thetransmission of that information using secure socket layer technology(“SSL”). While we take reasonable precautions against possiblesecurity breaches of our websites and our customer databases andrecords, no website or Internet transmission is completely secure, andwe cannot guarantee that unauthorized access, hacking, data loss, orother breaches will never occur. We urge you to take steps to keepyour personal information safe (including your account password), andto log out of your account after use. If your SNS account is hacked,this may lead to unauthorized use of your New Hill StrategicManagement Ltd. applications, so be careful to keep your accountinformation secure. If you have questions about the security of ourwebsites, please contact us at privacy@new-hill.co.uk. Unfortunately,the transmission of information over the Internet is not completelysecure. Although we strive to protect your personal data, we cannotguarantee the security of your data while it is being transmitted toour site; any transmission is at your own risk. Once we have receivedyour information, we have procedures and security features in place totry to prevent unauthorized access.
If we decide to make material changes to our Privacy Policy, we will notify you and other users by placing a notice on new-hill.co.uk or by sending you a notice to the e-mail address we have on file for you. We may supplement this process by placing notices in our applications and on other New Hill Strategic Management Ltd. websites. You should periodically check new-hill.co.uk and this privacy page for updates.
We do not share personal information with third parties for theirdirect marketing purposes unless you affirmatively agree to suchdisclosure, typically by “opting in” to receive information from athird party that is participating in a sweepstakes or other promotionon one of our sites. If you do ask us to share your personalinformation with a third party for its marketing purposes, we willonly share information in connection with that specific promotion, aswe do not share information with any third party (other than ourservice providers) on a continual basis. To prevent disclosure of yourpersonal information for use in direct marketing by a third party, donot opt in to such use when you provide personal information on one ofour sites.
Users in certain jurisdictions have a right to access personalinformation held about themselves. Your right of access can beexercised in accordance with applicable law. Please submit anyrequests for access to your personal data in writing toprivacy@new-hill.co.uk.
If you have any questions, comments or concerns regarding our PrivacyPolicy and/or practices, please send an e-mail toprivacy@new-hill.co.uk. All other inquiries should be directed toinfo@new-hill.co.uk.
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