Privacy Policy

 

Introduction

 

Welcome to Blockman Editor. Thank you for playing our games and using our Editor! This Privacy Policy describes:

The ways we collect personal data about you;

How we collect and use your personal data; and

The rights and choices you have about your personal data.

This Privacy Policy applies to all Blockman GO's games, Blockman Editor, websites, and related services (collectively, the “Services”).

 

Your continued use of the Services or Platform, including any transactions, shall constitute your continued acknowledgment and acceptance of the changes made to this Privacy Policy.

 

What Types of Information Do We Collect?

 

In providing the Services, we may collect and process personal information about you, including but not limited to the following:

Contact information, such as name, email, address, or phone numbers

Profile information, such as player name, user ID, and password

Photographs, images, or recordings you provide

Purchase and transaction data, including payment information

Chats or messages you send via the Service or to Customer Support

Other data you choose to give us

Data shared through linked accounts, social media accounts, or other partner services

Data about your account, your game usage and progress

Advertising and marketing data, including information about content and advertisements you interact with

Approximate location information, including IP information

Information about your device, internet service provider, mobile carrier, operating system, etc.

Information collected using cookies and other web technologies. Like many platform and website operators, we use data collection tools such as cookies and other similar technologies to collect certain information.

If you do no longer agree to this Privacy Policy and do not want us to collect information / personal data about you, you may opt out at any time by notifying our Data Protection Officer in writing as explained below.

How Will Your Data Be Used?

Our primary goals in collecting and processing user information are to provide our Services to you (to perform our contract with you), to communicate or allow other users to communicate with you, to improve our Services, to administer your use of the Services (including your account if applicable), to verify and confirm payments, to offer and provide products to you, to enable you to enjoy and easily navigate our Services, for marketing or advertising purposes in accordance with applicable law, for research, analytics, network and information security, and fraud prevention purposes, to respond to legal process or claims or requests from governmental authorities where applicable, to pursue other legitimate business and legal interests, to respond to and address messages sent to our Customer Service team, and to correspond with you and keep you updated regarding the Services (collectively, the “Purposes”).

Will Blockman Editor Share Your Data with Third Parties?

Apart from Blockman Editor, your data may be disclosed to third parties in certain situations for one or more of the above-stated Purposes:

Our affiliates and related companies.

To other players and users. Other players and users may, for example, see your profile data, in-game activities, information about the region from which you are playing, and the messages or other content you have posted.

To our service providers. Blockman Editor has vendors who help us to provide the Services. These vendors may process your data only in accordance with our instructions to provide the Services, and perform tasks such as hosting, player support, payment processing, advertising, analytics, fraud prevention, among other things.

To government authorities or in connection with legal claims or proceedings. We may process and disclose data with other companies and organizations and provide it to public authorities in response to legal process or other legal requests. We may also disclose your data based on your consent, to comply with the law, in response to regulators or governmental authorities, where we have a good faith belief disclosure is reasonably necessary to respond to a legal claim or request, and/or to protect the rights, property or safety of us, our players or others.

In connection with a corporate sale or transfer. We may provide data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all Blockman Editor’s assets.

To advertising and Social Media partners. Subject to applicable law, the Services may include features from our partners, such as social media tools, functionalities through application programming interfaces (APIs) or software development kits (SDKs). We may also combine and share data we have collected about you with third-party advertising partners. Where permitted, these advertising partners may use this data (and similar data collected from other websites) for purposes of delivering targeted or online behavioral advertisements to you when you visit third-party services. These advertising and social media partners may be able to access or use some of your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

To other third parties for the Purposes listed above.

The Services may contain links to websites and services that are owned or operated by third parties. Any information that you provide on or to these third-party services or that is collected by a third-party service provider is provided directly to the owner or operator of the third-party service and is subject to their own privacy policy. Blockman Editor is not responsible for the content, privacy or security practices and policies of any third-party service provider. To protect your information, we recommend that you carefully review the privacy policies of all third-party services that you access.

 

Cookies

 

“Cookies” are identifiers that are stored on your computer or mobile device that record data about your computer or device, how and when the Services are used or visited, by how many people and other activity. Cookies also link to information regarding what items you have selected for purchase and web pages you have viewed. We or our service providers / advertising partners may use cookies or similar features to allow us or third parties to collect or share information in connection with your use of the Services. These features help us improve the Services we offer, offer new features, and enable us and our advertising partners to serve more relevant content to you. We may link cookie information to personal data.

 

You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do so, you may not be able to use the full functionality of the Services.

 

Children

 

Protecting children’s right to privacy online is very important to us. We do not knowingly collect or maintain any personal data or non-personally identifiable information from anyone under the age of 13 (US) / 16 (Europe) nor is any part of our Platform or other Services directed to children under the age of 13 (US) / 16 (Europe). As a parent or legal guardian, please do not allow such children under your care to submit personal data to Blockman Editor. In the event that personal data of a child under the age of 13 (US) / 16 (Europe) in your care is disclosed to us, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Policy on their behalf. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13 (US) / 16 (Europe).

 

International Transfers

 

You agree that all personal information collected via or by Blockman Editor may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, Singapore, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Where applicable, your personal information may be accessible to law enforcement or other authorities having jurisdiction over us pursuant to a lawful request.

 

How Do We Protect Your Data?

 

To help ensure a secure and safe player experience, we take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your personal information) from unauthorized access, use, or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

 

We may retain your data for as long as your account is active, as needed to provide you the Services and for the Purposes listed above, or, where applicable, where there is another lawful basis to retain such data. Note that if you ask us to remove your personal data, we may, subject to applicable law, retain certain data as necessary for our legitimate business and legal interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Your Choices and Rights

 

We offer you certain controls and choices regarding the information we collect, how the information is used, and how it is shared. These controls and choices may include the ability to update, correct or delete information that you have provided to us or information that we have collected through your use of our services. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from us.

 

You may also opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications. The updated settings may not be effective immediately. Note that you may continue to receive non-promotional communications from us, such as communications regarding the Service or updates to our Terms of Service or this Privacy Policy.

 

Depending on your place of residence (for example, if you are a resident of the European Economic Area or United Kingdom), you may have the right, in accordance with applicable law, to request access to, deletion, and portability of your information. In addition, where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting our Data Protection Officer at editorpc@sandboxol.com. We will respond to all requests within a reasonable timeframe and will comply with verified data subject requests as required by law.

 

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may also contact your local data protection authority in your jurisdiction. For example, if you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

 

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on our services may change or no longer be available to you.

 

For California Residents

 

For purposes of the California Consumer Privacy Act, we do not “sell” personal information. In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of your personal information or ask us to send that information to another company; (iv) restrict our uses of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, depending on applicable law; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request erasure of personal information held about you by Blockman Editor, subject to certain exceptions prescribed by law. If you are a California resident, you have the right not to receive discriminatory treatment by us for the exercise of your rights conferred by the California Consumer Privacy Act.

 

If you would like to exercise any of these rights, please contact our DPO at the email address provided below. We will process such requests in accordance with applicable laws. To protect your privacy, we may take steps to verify your identity before fulfilling your request.

 

Your Privacy Rights if you live in the EEA , UK or Switzerland

If you live in the EEA , the UK or Switzerland , you may have additional "rights" when it comes to your personal information . You can ask us to:

 Tell you what information we have about you and what we do with it

 Fix your personal information if it’s incorrect

 Delete your information 

If you want to understand more, you can refer to the full Privacy Policy. If you have reason to, you can complain about how we are using your information by emailing us at editorpc@sandboxol.com . 

 

Privacy Policy Changes and Updates 

We may update this Privacy Policy from time to time and will update you of any changes in accordance with applicable law, including by contacting you or posting a new version through the Services. When we update it, we will revise the "Last Updated" date below. We will obtain prior parental consent if any changes we make to this Policy affect users under the age of 13 in a way that requires such consent under COPPA or the age of 16 (or as per the age derogation by Member States in their domestic law) or 13 in the UK, under the European and UK General Data Protection Regulation.

 

Contact Us

 

If you have questions about data protection or this Privacy Policy, or if you have any requests for resolving issues with your personal data, we encourage you to contact us at editorpc@sandboxol.com. You may also reach out to us through the support features within our games or via our website.

 

Privacy Policy for Europe

1. In the course of visiting our website and apps, and/or using our services and products, we may process the following Personal Information:

l Information relating to a job application made by you, like your name, emai address, employment details, CV, resume or other details of your employment history sent by you. We will process this information to process and respond to your job application. The legal basis for this processing activity is Article 6 sec.1 sent.1 lit. b GDPR (“necessary for entering into an employment contract with us”).

l Login information, which may include your IP address, device type, name, date and time of your visit, information on your browser version, information on your operating system, including language settings, MAC addresses, and User ID. We will process this information to provide you with our Service. The legal basis for this processing activity is Article 6 sec.1 sent.1 lit. b (“performance of a contract”) and lit. f (“legitimate interest”) GDPR. It is in our legitimate interest to guarantee the Services’ stability and security.

l Account information, e.g. information such as your name, username, login and password details, location information, user-generated content, contact details and other Personal Information that are used for participating in the Service we are offering. We process this information to provide our Services to you. The legal basis for this processing activity is Article 6 sec.1 sent.1 lit.b GDPR (“performance of a contract”).

l Email addresses you provided us with for added verification and/or to enable certain features. The bases for processing this personal data are Article 6 sec.1 sent.1 lit.b (“performance of a contract”) and f (“legitimate interest”) GDPR. Sandbox has a legitimate interest in providing a safe and secure Service, especially to protect children.

l Billing and payment information, when you participate in Developer Exchange or purchase virtual currency or premium subscriptions, including your name, billing address, credit card or other payment information and billing information. The legal basis for this processing activity is Article 6 sec.1 sent.1 lit.b GDPR (“performance of a contract”). We may also retain transaction details and purchase and payment history. The legal basis for processing these personal data is our legitimate interest in being able to resolve subsequent billing disputes and inquiries, Article 6 sec.1 sent.1 lit.f GDPR (“legitimate interest”).

l Information relating to contacting our customer service, e.g. when you report a problem, submit questions, concerns or comments. We may process your email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulfill your requests, or provide other customer support. This processing activity is based on your consent according to Article 6 sec.1 sent.1 lit. a GDPR and/or Article 6 sec.1 sent.1 lit.b GDPR (“performance of a contract”), depending on the initial purpose for contacting our customer support.

l Comments or messages you post or transmit on Sandbox via public chats, forums, group walls, personal post, etc. We process this information to monitor, filter and moderate this information for the purposes of being able to remove profanity, Personal Information, and other inappropriate conversations. Additionally, we may use pre-filtered comments and messages for other purposes such as training and improving our filter technology. The legal basis for this processing activity is Sandbox’s legitimate interest in being able to defend ourselves from possible liability claims that may arise from unlawful comments posted by you, Article 6 sec.1 sent.1 lit.f GDPR (“legitimate interest”). Please note that any Personal Information submitted by you in forums and similar means offered by us is available to anyone who has access to this forum including other users. The Personal Information posted by you can be read, collected or used by other users of these forums and could be used to send unsolicited messages.

l Information required for participating in our Developer Exchange Program. The legal basis for this processing is Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”) with regard to U. S. law requirements. It is our legitimate interest to comply with the legal requirements, especially with regard to U. S. anti-money laundering laws.

l Information relating to your use of or interaction with third party plug-ins, e.g. social plugins from Google, Facebook or Twitter. When you use these features, certain information from your social media accounts may be accessed by or shared with Sandbox, and likewise, certain information about your use of Sandbox may be posted to your profile on those platforms. The legal bases for this processing activity are Article 6 sec. 1 sent. 1 lit. a (“consent”) and f (“legitimate interest”) GDPR. We have a legitimate interest to improve your website experience and to optimize our service.

l Information processed to enable advertising. To market our services, inter alia, via social media platforms in order to bring new users to our websites and to maintain and increase our user base, we may process Personal Information such as IP addresses, information on users’ browser or operating system, including language settings, location information and user names or user IDs. The legal basis for the processing of this data is Sandbox’s legitimate interest in maintaining our user base, bringing new users to our websites and informing (potential) users about interesting events, Art. 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

l Information relating to the use of location-based service. In order to provide Services such as tagging, check-in and content delivery, or other services that require knowing where you are, we may process your location information. This processing is based on Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”) and/or Article 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”) and represents our legitimate interest to improve your website experience and to optimize our services. Please note that you can always stop the collection of location information by updating your device settings, stopping to use the Service, or uninstalling our mobile applications.

l Information relating to your participation in contests, competitions, sweepstakes, giveaways, prize draws or other promotions that we may run on our Service or sponsor from time to time. We may process certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).

l Cookies. We will use certain cookies only if you have previously consented to such use. When you visit our website with an EEA IP address, a cookie banner will appear asking you for your consent. You can manage your choice by clicking on “manage cookie preferences” in the cookie banner. We will save your choices in the form of a cookie. This cookie has a limited effective period of one year. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. a GDPR (“consent”). In addition, you can also manage cookies using your browser settings.

2. Please note that we do not use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

l Personal data of children. Please note that when users under the age of 13 register for the Service, their account is automatically set to “Privacy Mode. ” This means that these users will not have access to certain features, such as social media plug-ins, some forms of third party advertising, and certain types of notification alerts. When a child creates an account on Sandbox, we may process a username, password, birthdate and parent email address. We process this information to give the user access to the Service and to communicate with the parent about the minor’s account (if a parent email was provided). For example, we may use the parent’s email to send an email notification about the child’s account creation and an invitation for the parent to review, update settings, and approve of their child's account. We may use the birthdate the child provides when signing up for the Service to determine which features on Sandbox the child should have access to and to determine when the child will turn 13 years old and can be given broader access to features on our Service. This processing activity is based on Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”). In general, we will not use or share account information (including Personal Information) from a minor’s account except for the permissible purposes stated in this Privacy Policy, and, if required by law, only with the prior verifiable consent of a parent or legal guardian (Article 6 sec. 1 sent. 1 lit. a and Article 8 sec. 1 GDPR).

l Data sharing. Sandbox may share users' information, including Personal Information like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Sandbox’s behalf. These providers may operate or support certain functions of the Service. Below is an illustrative list of functions for which we may use third party service providers and the names of the providers we may use to perform these functions:

Ø Analytics services (e. g., Google Anaylisis, AWS Kenisis);

Ø User Acquisition services (e. g., AppsFlyer);

Ø Community filtering and moderation services (e. g., Qiniu);

Ø Customer support services (e. g., Feedback);

Ø Social Media Log-in (e. g., Facebook GMail Twitter);

Ø Billing services and payment gateway providers (e. g., Google, Apple); and

Ø Hosting and content delivery network services (e. g., AWS)

 

3. The legal basis for this data transfer and processing activity is Article 28 of GDPR in conjunction with the data processing agreements we concluded with respective third-party agents. These agents and contractors are only allowed to use the information shared with them only for the specific tasks they’ve been hired to do and consistent with this Privacy Policy, and for no other purposes. Sandbox takes steps to ensure that all service providers with access to Personal Information are capable of protecting the information we share with them.

l Legal disclosure. We may disclose Personal Information about you, including the content of your communications on the Service, to comply with legal process, including court orders and subpoenas, served on our Service. In addition, we also may disclose Personal Information about you, including content, in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services), or if such disclosure may (i) prevent the instigation of a crime, (ii) facilitate an investigation related to public safety or protect the safety of a child using our Service, (iii) protect the security or integrity of our Service, or (iv) enable us to take precautions against liability or to protect our rights. The legal basis for such disclosure is Article 6 sec. 1 sent. 1 lit. c (“compliance with legal obligation”) in compliance with the respective EEA or Member State law and lit. f (“legitimate interest”) GDPR. It is our legitimate interest to comply with the legal requirements of U. S. law.

l Storage and international transfer of your Personal Information. Sandbox is based in the Singapore. Your Personal Information that we collect is sent to and stored on secure servers located in the United States of America. Such storage is necessary in order to process the information. Some of our agents and third-party service providers are located outside the European Economic Area, e. g. the United States. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your country of residence. Wherever we transfer your Personal Information, we will take reasonable steps to ensure that your privacy rights continue to be protected, e. g. conclude the EU Standard Contractual Clauses with third parties.

l Your rights. If you are a user based in the European Economic Area, you may be entitled to exercise some or all of the following rights:

Ø Require (i) information whether your Personal Information is retained and (ii) access to or duplicates of your Personal Information retained, including the purposes of the processing, the categories of Personal Information concerned, and the data recipients as well as potential retention periods;

Ø Request rectification, removal or restriction of your Personal Information, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;

Ø Refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your Personal Information at any time;

Ø Object, on grounds relating to your particular situation, to processing of your Personal Information, in case such processing is either based on our or a third party's legitimate interests or on a performance of a task carried out in the public interest. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your Personal Information or present you our compelling legitimate grounds for an ongoing processing;

Ø Object to the use of your Personal Information for direct marketing at any time;

Ø Take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data protection regulators; and/or

Ø Require (i) to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side. Where technically feasible you shall have the right to have the Personal Information transmitted directly from us to another controller.

 

4. You may (i) exercise the rights referred to above, (ii) pose any questions, or (iii) make any complaints regarding our data processing by contacting us.