We, the above-named controller (“we”, “us”) is committed to protecting personal data concerning you, and
respecting your privacy.
When you use our products and services, including websites such as tripledot.com, or mobile apps, we
will process certain personal data that concerns you. ‘Process’ or ‘processing’ as used in this Privacy
Notice includes any operation performed on personal data or on sets of personal data, like collection,
storage, organisation, retrieval, updating, amending, deletion, consultation, use, sharing or making
available internally or to others.
This Website and App Users Website Privacy Notice (“Privacy Notice”) sets out details of the processing
we carry out, the purpose of the processing, the legal basis for the processing, our legal obligations
as controller, and your rights in relation to that processing.
Who Are We?
Two Bears develops and publishes social games and applications for the web and mobile devices. “Two
Bears,” or “we” or “us” refers to Two Bears Technology Co., Ltd. Beijing. This Privacy Notice covers
processing by Two Bears itself, and members of the Two Bears Group which comprises Two Bears’s
subsidiaries, parent companies, joint ventures and other corporate entities under common ownership or
control and/or any of their agents, consultants, employees, officers and directors.
Personal data we may collect from you and how we process it
If you visit one of our websites
Online identifiers, electronic network activity, location data including country code data, and
data concerning the usage of company’s systems (including of external websites)
Answers to online surveys and questionnaires, and partner votes
Third party identifiers including those issued by Facebook and other social media platforms.
IP Address We will process this information in order to:
Give you access to the website
Enhance your experience
Improve the experience of all our users.
See also the information on cookies below and the cookie policy and cookie consent on the relevant
website.
If you use one of our mobile apps
All the above information plus:
Apple, Google User ID
Specific user behaviour characteristics
Preferences including advertising preferences
the name you have associated with your device
your country
your specific geolocation
information about Two Bears and other third-party apps you have on your device
a Two Bears player ID number that is created by Two Bears and used to identify you
We will process this information in order to:
optimise your experience
secure your user data and personal data
improve our mobile apps
In some cases we will ask your permission before requesting access to this personal data in the context
in which it is processed within the app. The level of access may also depend on your device’s privacy
settings which can be adjusted on the settings menu of your device.
If you contact us, or if you register your details with us
Any of the above information plus:
Personal and identification details, including first, last and middle names, age and date of
birth
Your experiences and opinions using our products and services
Contact information including address, telephone/mobile number, e-mail address
game username(s) and avatars
your gender
approximate location information that you provide
links to your profiles on various social network
details about the games you play
We will process this information in order to:
Manage your account and user preferences
Protect your personal data, and other information, from disclosure to other users.
Enhance your experience
to create your game accounts and allow you to play our games
to identify and suggest connections with other our players and personalise our Services to you
to enable players to communicate with each other
to provide technical support and respond to player enquiries
to protect the safety and well-being of our players
to protect Two Bears’s rights and property in connection with our services;
to prevent fraud or potentially illegal activities
to notify players of in-game updates, new products or promotional offers
to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events
sponsored or managed by us or our business partners
to comply with our legal obligations, resolve any disputes we may have with you or other
players, and to enforce our agreements with third parties
to conduct research
Personal data we may collect from other sources and how we process it
If you access one of our mobile apps using third-party authentication, access any of our other Services
on connected third-party applications, or connect our Services to any third-party applications
This includes including social networks like Facebook or Instagram, We may receive certain information
about you from the provider of the third-party application. The information we receive depends on the
our game you’re playing, the third-party application, your privacy settings and, if applicable, your
friends’ privacy settings on that third-party application. IN most cases you will be given an
opportunity to allow or deny this access in the context in which it is requested.
In addition to the information set out above, we may receive and process the following:
your profile picture or its URL
your user ID number (like your Facebook ID number), which may be linked to publicly-available
information like your name and profile photo
the user ID number and other public data for your friends
the login e-mail you provided to that third-party application when you registered with it
your physical location and that of the devices you use to access our services
your gender
your birthday and/or age range
information about your activities on or through the connected third-party application
other publicly-available information on the third-party application
any other information that you or the provider of the third-party application share with us
We will process this information in order to:
Identify you
Provide you with the app or other service
Connect and streamline your experience between our service and that of the third party
If you access our Services from a third-party application or connect our Services to a third-party
application, you should also read that third-party application’s Terms of Service and Privacy Policy.
If you are unclear about what information a third-party application is sharing with us, please go to the
third-party application to find out more about their privacy practices.
Lawful basis of processing
We process all of the above data in the pursuit of our legitimate business interests, including the
pursuit of new business, new customers and revenue streams, as well as the development of new, improved
apps and games and building our share of the market, our reputation and brands.
In some cases we also need to process the personal data pursuant to a contract with you or a third
party, such as Apple or Google, or to comply with a legal obligation.
Where we have not indicated that a lawful basis other than legitimate interest applies, you are entitled
to object to the processing of the persona data.
Special category personal data
We do not normally process any personal data concerning your racial or ethnic origin, political
opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic
data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or
data concerning a natural person’s sex life or sexual orientation, nor any information concerning
criminal convictions and offences.
If any app or other service ever requires us to process such personal data, you will be informed in
advance about this processing and its purpose, and we will either seek your explicit consent, or inform
you of the other lawful basis for this processing and give you the opportunity to opt out. This may mean
you are not able to use the specific app or other service to which this processing relates.
Cookies, analytics and automated information collection
We and service providers acting on our behalf, like Google Analytics, store log files and use tracking
technologies such as:
cookies, which are small pieces of data transferred to your mobile device or computer for
record-keeping purposes;
web beacons, which let us know if a certain page was visited or whether an e-mail was opened;
tracking pixels, which allow us or our advertising partners to advertise more efficiently and
effectively; and
local shared objects, also known as flash cookies, which help us to reduce fraud, remember your
in-game preferences and speed up load times.
We and our service providers use these log files, tags, and tracking technologies to collect and
analyze certain kinds of technical information, including:
IP addresses;
the type of computer or mobile device you are using;
your operating system version;
your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA),
and/or
International Mobile Equipment Identity (IMEI);
your browser types;
your browser language;
referring and exit pages, and URLs;
platform type;
the number of clicks on a page or feature;
domain names;
landing pages;
pages viewed and the order of those pages;
the amount of time spent on particular pages; and
game state and the date and time of activity on our websites or games.
Personal data concerning you that we may process on behalf of others
For a personalized advertisement experience, the advertising networks and their partners, some of which
are listed below may collect or receive device information from our apps and other apps that include
personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other
information regarding the delivery of advertisements and your interaction with them, inventory of
installed apps and/or other tracking technologies to provide measurement services, personalization, ad
selection, delivery, reporting, and optimize targeted ads. You can learn more about how each handles
your data by accessing their respective privacy notices using the hyperlinks below.
How We Share Your Informations
We may disclose or publish aggregated information (information about you and other players collectively
that is not intended to specifically identify you, for example, players between the ages of 21 and 25
who live San Francisco) and other non-personal information about our players for industry analysis,
demographic profiling, marketing, analytics, advertising, and other business purposes.
In addition, we may share your information (which may include personal information) with third parties
(in other words, parties other than Two Bears) or allow third parties to collect this information from
our Services
Privacy policies of linked third-party services and advertisers
Our websites and games may contain advertisements from Third-Party Services, which are companies other
than Two Bears that may link to their own websites, online services or mobile applications. We are not
responsible for the privacy practices or the content of these Third-Party Services. If you have any
questions about how these Third-Party Services use your information, you should review their policies
and contact them directly.
Our policies concerning children
Most of our websites and games are not for children under the age of 13 and we do not knowingly collect
any personal information from children under 13. Children under 13 should not use these websites or
games at any time. If we learn that we have inadvertently gathered personal information from a child
under 13, we will take reasonable measures to promptly remove that information from our records. Two
Bears may also provide games which are intended for users of all ages.
How long we keep your information
How long we retain your information depends on why we collected it and how we use it. We will not retain
your personal information for longer than is necessary for our business purposes or for legal
requirements. For instance, we may retain some information for a few years after you have closed your
account with us if this is necessary to meet our legal obligations or to exercise, defend or establish
legal rights.
Security of your information
We implement security measures to help protect the security of your information both online and offline.
We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
These measures vary based upon the sensitivity of your information.
Your rights
The applicable data protection laws give you certain specific rights in relation to the processing of
personal data that concerns you.
Please note that not all these apply in all circumstances. However, you are always welcome to contact us
with any request relating to processing of your personal data. Even where we are not obliged by law to
comply with your request, we will try to accommodate your wishes.
Access – you have the right to access personal data concerning you and certain information about
how and why we are processing it;
Rectification – you have the right to have any inaccurate or incomplete personal data rectified
without undue delay;
Erasure – Sometimes called the ‘right to be forgotten’, in certain circumstances, you have the
right to have personal data that concerns you erased without undue delay;
Restriction – in certain circumstances, you have the right to have our processing of personal
data concerning you restricted;
Data portability – in certain limited circumstances, you have the right to receive any personal
data concerning you that you have provided to us, in a structured, commonly-used and
machine-readable format, and the right to transmit those data to another controller without
hindrance; and
Objection – in certain circumstances, you have the right to object to the processing of personal
data carried out by us or on our behalf where it concerns you.
Contact Us
If you would like further information on anything in this Privacy Notice, for all questions or concerns
you have about your personal data, or if you think you would like to exercise any of your rights as a
data subject, please contact us using the contact details at the top of this Privacy Notice.
Facebook Audience Network is an advertising service provided by Facebook, Inc. (US) that may collect or
receive information from our apps and other apps and use that information to provide measurement
services and targeted ads.
Privacy Policy: https://www.facebook.com/about/privacy/
Google AdSense
Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the
DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our
Service or other websites on the Internet
You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the
Google Ads Settings web page: http://www.google.com/ads/preferences/
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. (US) that connects
data from the Facebook advertising network with actions performed on this Application.
Privacy Policy: https://www.facebook.com/about/privacy/
Firebase
Firebase is analytics service provided by Google Inc. (US)
You may opt-out of certain Firebase features through your mobile device settings, such as your device
advertising settings or by following the instructions provided by Google in their Privacy Policy:
http://www.google.com/intl/en/policies/privacy/