Glu Mobile Privacy Policy - Past Versions

Last updated: August 12, 2020

January 1, 2020

What’s Changed: We’ve added information regarding the California Consumer Privacy Act of 2018 (CCPA) and consolidated our General Data Protection Regulation (GDPR) statements into a single document for ease of reference.

This Privacy Policy explains how information about you is collected, used and disclosed by Glu Mobile Inc. and its subsidiaries (“Glu,” “we” or “us”). This Privacy Policy applies to information we collect when you use our websites, mobile applications and other online products and services (collectively, the “Services”). This Privacy Policy does not apply to the information collected from: (1) web-based applications that are based on our mobile applications but are published by third parties, (2) mobile applications that we distribute on behalf of third parties and which are hosted and operated by such parties, or (3) the on-line submission of resumes and employment applications in connection with the Jobs section of our website.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as by adding a statement to our homepage or mobile applications or by sending you an email notification). We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you are located in the United Kingdom, Switzerland or the European Economic Area (EEA), please see our Supplemental EEA+ Privacy Statement here – https://www.glu.com/eea-privacy-statement

If you are a resident of California, please also see our Supplemental California Consumer Privacy Act Disclosures here – https://www.glu.com/caprivacy

Collection of Information

1. INFORMATION YOU PROVIDE TO US

We collect information you provide directly to us. For example, we collect information when you create an account, manage your user profile, participate in any interactive features of the Services, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The types of information we collect include your name, email address, postal address, photograph, avatar, password, phone number, username, gender, birth day, forum posts and comments, messages between users and other contact or identifying information you choose to provide, but, as you’ll see when you interact with one or more of the Services, the exact types of information we collect will depend on the Service you choose to use. Prize winners of contests or sweepstakes may also have to provide their Social Security Numbers, which are used exclusively for prize fulfillment and related tax purposes.

2. INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES

When you access or use our Services, we automatically collect information about you, including:

Device Information:

We collect device-specific information when you access our Services from a mobile device, including your hardware model, operating system and version, unique device identifiers, mobile network information and country, language, screen size and resolution, and battery life remaining.

Use Information:

We collect information about your use of the Services, including the type of browser you use, access times, pages viewed, game play activity, interactions with other players, your IP address and, with respect to our website, the page you visited before navigating to our Services.

Information Collected by Cookies and Other Tracking Technologies:

We use various technologies to collect information, and this includes sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. We also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that are used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

For more information about the cookies and similar technologies we use, please see our Cookie Notice here – https://www.glu.com/cookie-notice. For more information about how to disable them, please see “Your Choices” below.

Other Information Collected with Permission:

Our mobile applications that are distributed through various “app” stores also request permission to automatically collect other information from your mobile device, including your email address. We only collect this information with your authorization in accordance with your device operating system’s permission process.

3. INFORMATION WE COLLECT FROM OTHER SOURCES

We also obtain information from other sources and combine that with information we collect through our Services. For example, if you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information, profile picture, phone number, email address, gender, date of birth and friends lists, in accordance with the authorization procedures determined by such social media site.

Use of Information

We use information about you for various purposes, including to:

Provide, maintain and improve our Services;
Setup your gWallet account and manage the Glu credits that you earn and use across our Services;
Provide and deliver the products and services you request and send you related information, including confirmations and invoices;
Send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Monitor and analyze trends, usage and activities in connection with our Services;
Personalize and improve the Services and provide advertisements, content, suggested connections or features that match user profiles or activities;
Process and deliver contest entries and rewards; and
Carry out any other purpose for which you consent at the time of collection.

Sharing of Information

We share information about you as follows or as otherwise described in this Privacy Policy:

With vendors, consultants and other service providers who need access to such information to provide services to us or to you;
With other users of the social features of the Services. For example, your username, profile picture and the virtual content you have accumulated in a game may be visible to other users of that game. Additionally, information that you provide in your account registration for a forum and your forum comments may be available to other forum users.
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Glu or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or
With your consent or at your direction.

We also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

The Services offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Analytics, Advertising and Other Services Provided by Other Companies

We allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as rewards programs and tournaments. These third parties may use cookies, web beacons, your account information (that you set up with these third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your IP addresses, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked, and conversion information. These third parties may also share this information with their customers and clients. This information may be used by Glu, and these other companies and their customers and clients, to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your usage. Some of these third-party analytics and advertising services offer you a choice to opt out of the collection of and/or sharing of this information; links to the opt-out mechanisms for the third parties that offer such a choice can be found in the “Your Choices” section below. This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies. In addition, if you click on ads shown on our Services, download third-party apps, or otherwise engage with third parties, you send your personal information to third parties. We do not control the data processing practices of third-party advertisers and recommend that you review the advertisers’ privacy policies before sending personal information to them.

Security

Glu takes measures intended to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Choices

Website (Game Forums) Account Information

You may update, correct or delete your website (game forums) account information, which includes your username, password, email address and avatar, by logging into your website account and managing your profile. If you wish to delete or deactivate your website account, please email us at privacy@glu.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your website account information for a certain period of time.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Push Notifications

With your consent, we send push notifications (or “alerts”) to your mobile device to provide game activity information, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.

Promotional Communications

You may opt out of receiving promotional messages from Glu by following the instructions in those messages or by contacting us at privacy@glu.com. If you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

Third Party Analytics and Advertising Services

We have identified the provider names of some of the third-party analytics and advertising services we use. Please see the links on this pageto learn more about the data practices of our third-party service providers (including opt-out mechanisms they may offer). You can also use your device settings to manage interest-based advertising that appears on mobile applications; to do so, select “limit ad tracking” on Apple iOS operating systems and “opt-out of interest-based ads” on Android operating systems.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

We adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Framework Principles issued by the U.S. Department of Commerce (the “Principles”) in connection with personal data received from the EEA and Switzerland in reliance on the Principles. We also receive some data in reliance on other compliance mechanisms, including agreements based on the EU standard contractual clauses. For more information about the Principles and to view our certifications, please visit the Department of Commerce’s Privacy Shield websiteat https://www.privacyshield.gov/welcome

Our accountability for personal data that we receive under the Principles and subsequently transfer to a third party is described in the Principles. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. With respect to personal data received or transferred pursuant to the Principles, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

You may contact us about any question or complaint regarding adherence to the Principles as indicated in the “Contact Us” section below. If we do not resolve your complaint, you may submit your complaint free of charge to our U.S.-based third party dispute resolution provider at https://feedback-form.truste.com/watchdog/request. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint.

Contact Us

If you have any questions about this Privacy Policy, please contact us at: Privacy Policy Administrator. You may also contact our Privacy Policy Administrator by writing to:

Glu Mobile Inc.

875 Howard Street, Suite 100

San Francisco, CA 94103

July 9, 2018

What’s Changed: Please note the changes in the definition of “Glu,” changes in “Sharing Your Information,” “Analytics, Advertising and Other Services Provided by Other Companies” and in “Your Choices” below.

This Privacy Policy explains how information about you is collected, used and disclosed by Glu Mobile Inc. and its subsidiaries (“Glu,” “we” or “us”). This Privacy Policy applies to information we collect when you use our websites, mobile applications and other online products and services (collectively, the “Services”). This Privacy Policy does not apply to the information collected from: (1) web-based applications that are based on our mobile applications but are published by third parties, (2) mobile applications that we distribute on behalf of third parties and which are hosted and operated by such parties, or (3) the on-line submission of resumes and employment applications in connection with the Jobs section of our website.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, manage your user profile, participate in any interactive features of the Services, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, photograph, avatar, password, forum posts and comments, messages between users and other contact or identifying information you choose to provide. Prize winners of contests or sweepstakes may also have to provide their Social Security Numbers, which are used exclusively for prize fulfillment and related tax purposes.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect information about you, including:

Device Information:
We collect device-specific information when you access our Services from a mobile device, including your hardware model, operating system and version, unique device identifiers, mobile network information and country.

Use Information:
We collect information about your use of the Services, including the type of browser you use, access times, pages viewed, game play activity, interactions with other players, your IP address and the page you visited before navigating to our Services.

Information Collected by Cookies and Other Tracking Technologies:
We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Other Information Collected with Permission:
Our mobile applications that are distributed through various “app” stores may also request permission to automatically collect other information from your mobile device, including your email address. We may only collect this information with your authorization in accordance with your device operating system’s permission process.

Information We Collect From Other Sources

We may also obtain information from other sources and combine that with information we collect through our Services. For example, if you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information, profile picture, phone number, email address, gender, date of birth and friends lists, in accordance with the authorization procedures determined by such social media site.

Use of Information

We may use information about you for various purposes, including to:

Provide, maintain and improve our Services;
Setup your gWallet account and manage the Glu credits that you earn and use across our Services;
Provide and deliver the products and services you request and send you related information, including confirmations and invoices;
Send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Monitor and analyze trends, usage and activities in connection with our Services;
Personalize and improve the Services and provide advertisements, content, suggested connections or features that match user profiles or activities;
Process and deliver contest entries and rewards;
Link or combine with information we get from others to help understand your needs and provide you with better service; and
Carry out any other purpose for which the information was collected.

Glu is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
With other users of the in connection with the social features of the Services. For example, your username, profile picture and the virtual content you have accumulated in a game may be visible to other users of that game. Additionally, information that you provide in your account registration for a forum and your forum comments may be available to other forum users.
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Glu or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or
With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Analytics, Advertising and Other Services Provided by Other Companies

We may allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as rewards programs and tournaments. These third parties may use cookies, web beacons, your account information (that you set up with these third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your IP addresses, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked, and conversion information. These third parties may also share this information with their customers and clients. This information may be used by Glu, and these other companies and their customers and clients, to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your usage. Some of these third-party analytics and advertising services offer you a choice to opt out the collection of and/or sharing of this information; links to the opt-out mechanisms for the third parties that offer such a choice can be found in the “Your Choices” section below. This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies.

Security

Glu takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Choices

Website Account Information
You may update, correct or delete your website account information, which includes your username, password, email address and avatar, by logging into your website account and managing your profile. If you wish to delete or deactivate your website account, please email us at
privacy@glu.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your website account information for a certain period of time.

Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Push Notifications
With your consent, we may send push notifications (or “alerts”) to your mobile device to provide game activity information, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.

Promotional Communications
You may opt out of receiving promotional messages from Glu by following the instructions in those messages or by contacting us at privacy@glu.com. If you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

Third Party Analytics and Advertising Services
We have identified the provider names of some of the third-party analytics and advertising services we use. Please see the links below to learn more about the data practices of our third-party service providers (including opt-out mechanisms they may offer):

AdColony: https://www.adcolony.com/privacy-policy/
Google AdMob: https://www.google.com/intl/en/policies/privacy/
MoPub: https://www.mopub.com/legal/privacy/
AppLovin: https://www.applovin.com/privacy
Conversant Media: https://www.conversantmedia.com/legal/privacy
Facebook Audience Network: https://www.facebook.com/policy.php
Yahoo! Flurry: https://policies.yahoo.com/us/en/yahoo/privacy/products/developer/index.htm
InMobi: https://www.inmobi.com/privacy-policy/
LifeStreet: http://www.lifestreet.com/privacy/
UnityAds: https://unity3d.com/legal/privacy-policy
Vungle: https://vungle.com/privacy/
Aerserv: https://www.aerserv.com/privacy-policy/
Flurry: https://dev.flurry.com/secure/optOut.do
Nanigans: http://www.nanigans.com/privacy-policy/
TapJoy: http://info.tapjoy.com/about-tapjoy/privacy-policy/

Contact Us

If you have any questions about this Privacy Policy, please contact us at: Privacy Policy Administrator. You may also contact our Privacy Policy Administrator by writing to:
Privacy Policy Administrator
Glu Mobile Inc.
875 Howard Street, Suite 100
San Francisco, CA 94103
For The Swift Life supplemental privacy policy, click here.

***

May 30, 2018

What’s Changed: We’ve added a new section for EEA residents at the end of the Privacy Policy.

Collection of Information

INFORMATION YOU PROVIDE TO US

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES

When you access or use our Services, we automatically collect information about you, including:

Device Information:

Use Information:

Information Collected by Cookies and Other Tracking Technologies:

We use various technologies to collect information, and this includes sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below. We also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that are used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Other Information Collected with Permission:

INFORMATION WE COLLECT FROM OTHER SOURCES

Use of Information

We use information about you for various purposes, including to:

Provide, maintain and improve our Services;
Setup your gWallet account and manage the Glu credits that you earn and use across our Services;
Provide and deliver the products and services you request and send you related information, including confirmations and invoices;
Send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Monitor and analyze trends, usage and activities in connection with our Services;
Personalize and improve the Services and provide advertisements, content, suggested connections or features that match user profiles or activities;
Process and deliver contest entries and rewards; and
Carry out any other purpose for which you consent at the time of collection.

Sharing of Information

We share information about you as follows or as otherwise described in this Privacy Policy:

With vendors, consultants and other service providers who need access to such information to provide services to us or to you;
With other users of the social features of the Services. For example, your username, profile picture and the virtual content you have accumulated in a game may be visible to other users of that game. Additionally, information that you provide in your account registration for a forum and your forum comments may be available to other forum users.
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Glu or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or
With your consent or at your direction.

We also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

Analytics, Advertising and Other Services Provided by Other Companies

We allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as rewards programs and tournaments. These third parties may use cookies, web beacons, your account information (that you set up with these third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your IP addresses, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked, and conversion information. These third parties may also share this information with their customers and clients. This information may be used by Glu, and these other companies and their customers and clients, to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your usage. Some of these third-party analytics and advertising services offer you a choice to opt out the collection of and/or sharing of this information; links to the opt-out mechanisms for the third parties that offer such a choice can be found in the “Your Choices” section below. This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies.

International

The information we collect about you may be transferred to, and accessed from within, the United States, which may not offer the same level of data protection as your home jurisdiction. We will take steps to maintain an adequate level of protection for this information in the jurisdictions in which we process it. Adequate safeguards that our service providers may use include standard contractual clauses approved by the EU Commission and the EU-U.S. and Swiss-U.S. Privacy Shield certifications in case of transfers to the United States.

Security

Glu takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

YOUR CHOICES

Website (Game Forums) Account Information

Cookies

Push Notifications

Promotional Communications

You may opt out of receiving promotional messages from Glu by following the instructions in those messages or by contacting us at privacy@glu.com.If you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

Third Party Analytics and Advertising Services

We have identified the provider names of some of the third-party analytics and advertising services we use. Please see the links on this page to learn more about the data practices of our third-party service providers (including opt-out mechanisms they may offer). You can also use your device settings to manage interest-based advertising that appears on mobile applications; to do so, select “limit ad tracking” on Apple iOS operating systems and “opt-out of interest-based ads” on Android operating systems.

Contact Us

If you have any questions about this Privacy Policy, please contact us at: Privacy Policy Administrator. You may also contact our Privacy Policy Administrator by writing to:

Glu Mobile Inc.

875 Howard Street, Suite 100

San Francisco, CA 94103

For The Swift Life supplemental privacy policy, click here.

For an archive of past Glu Mobile privacy policies, click here.

NOTE TO EEA RESIDENTS

If you are a resident of the EEA, you have certain rights and protections under the law regarding our processing of your personal data. Please see the sections below for more details.

Legal Basis for Processing

We will only process personal data about you in accordance with the following legal bases:

As necessary to perform our responsibilities under our contract with you. For example, to process your order and fulfill the products or services you purchase.
When we have a legitimate interest in processing your personal data. For example, to communicate with you about changes to our Services or legal documents, to prevent fraud, to deliver advertising, provide, protect and improve our products and services.
If we request your consent to a specific processing activity (such as to send you marketing emails), and you provide your consent in the manner indicated.
In some cases, processing will be necessary for compliance with a legal obligation, such as response to legal process requests.

Data Subject Requests

You have the right to access personal data we hold about you and to ask that this data be corrected. In certain cases, you may also have the right to request that we erase data we are processing or to restrict or object to certain of our processing activities. You may also have the right to request that we provide you with the personal data you have provided us in a portable form for transmission to another controller’s service. If you would like to exercise any of these rights, you may contact us as indicated above.

Data Retention

We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

***

July 9, 2018

What’s Changed: We’ve added contact information for our EU Representative.

Collection of Information

INFORMATION YOU PROVIDE TO US

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES

When you access or use our Services, we automatically collect information about you, including:

Device Information:

Use Information:

Information Collected by Cookies and Other Tracking Technologies:

We use various technologies to collect information, and this includes sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below. We also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that are used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Other Information Collected with Permission:

INFORMATION WE COLLECT FROM OTHER SOURCES

Use of Information

We use information about you for various purposes, including to:

Provide, maintain and improve our Services;
Setup your gWallet account and manage the Glu credits that you earn and use across our Services;
Provide and deliver the products and services you request and send you related information, including confirmations and invoices;
Send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Monitor and analyze trends, usage and activities in connection with our Services;
Personalize and improve the Services and provide advertisements, content, suggested connections or features that match user profiles or activities;
Process and deliver contest entries and rewards; and
Carry out any other purpose for which you consent at the time of collection.

Sharing of Information

We share information about you as follows or as otherwise described in this Privacy Policy:

With vendors, consultants and other service providers who need access to such information to provide services to us or to you;
With other users of the social features of the Services. For example, your username, profile picture and the virtual content you have accumulated in a game may be visible to other users of that game. Additionally, information that you provide in your account registration for a forum and your forum comments may be available to other forum users.
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Glu or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or
With your consent or at your direction.

We also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

Analytics, Advertising and Other Services Provided by Other Companies

We allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as rewards programs and tournaments. These third parties may use cookies, web beacons, your account information (that you set up with these third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your IP addresses, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked, and conversion information. These third parties may also share this information with their customers and clients. This information may be used by Glu, and these other companies and their customers and clients, to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your usage. Some of these third-party analytics and advertising services offer you a choice to opt out the collection of and/or sharing of this information; links to the opt-out mechanisms for the third parties that offer such a choice can be found in the “Your Choices” section below. This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies.

International

Security

Glu takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

YOUR CHOICES

Website (Game Forums) Account Information

Cookies

Push Notifications

Promotional Communications

Third Party Analytics and Advertising Services

We have identified the provider names of some of the third-party analytics and advertising services we use. Please see the links on this page to learn more about the data practices of our third-party service providers (including opt-out mechanisms they may offer). You can also use your device settings to manage interest-based advertising that appears on mobile applications; to do so, select “limit ad tracking” on Apple iOS operating systems and “opt-out of interest based ads” on Android operating systems.

Contact Us

If you have any questions about this Privacy Policy, please contact us at: Privacy Policy Administrator. You may also contact our Privacy Policy Administrator by writing to:

Glu Mobile Inc.

875 Howard Street, Suite 100

San Francisco, CA 94103

For EEA Residents: please contact our EU Representative at EURep@glu.com.

For an archive of past Glu Mobile privacy policies, click here.

For The Swift Life supplemental privacy policy, click here.

NOTE TO EEA RESIDENTS

If you are a resident of the EEA, you have certain rights and protections under the law regarding our processing of your personal data. Please see the sections below for more details.

Legal Basis for Processing

We will only process personal data about you in accordance with the following legal bases:

As necessary to perform our responsibilities under our contract with you. For example, to process your order and fulfill the products or services you purchase.
When we have a legitimate interest in processing your personal data. For example, to communicate with you about changes to our Services or legal documents, to prevent fraud, to deliver advertising, provide, protect and improve our products and services.
If we request your consent to a specific processing activity (such as to send you marketing emails), and you provide your consent in the manner indicated.
In some cases, processing will be necessary for compliance with a legal obligation, such as response to legal process requests.

Data Subject Requests

Data Retention

Questions or Complaints

***

August 29, 2014

What’s Changed: Please note the changes the definition of “Glu,” changes in “Sharing Your Information,” “Analytics, Advertising and Other Services Provided by Other Companies” and in “Your Choices” below.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, manage your user profile, participate in any interactive features of the Services, request our e-newsletter or other marketing communications, participate in a promotion or survey, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, photograph, avatar, password, forum posts and comments, messages between users and other contact or identifying information you choose to provide. Prize winners of contests or sweepstakes may also have to provide their Social Security Numbers, which are used exclusively for prize fulfillment and related tax purposes.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect information about you, including:

Device Information: We collect device-specific information when you access our Services from a mobile device, including your hardware model, operating system and version, unique device identifiers, mobile network information and country.
Use Information: We collect information about your use of the Services, including the type of browser you use, access times, pages viewed, game play activity, interactions with other players, your IP address and the page you visited before navigating to our Services.
Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see “Your Choices” below. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
Other Information Collected with Permission: Our mobile applications that are distributed through various “app” stores may also request permission to automatically collect other information from your mobile device, including your email address. We may only collect this information with your authorization in accordance with your device operating system’s permission process.

Information We Collect From Other Sources

Use of Information

We may use information about you for various purposes, including to:

Provide, maintain and improve our Services;
Setup your gWallet account and manage the Glu credits that you earn and use across our Services;
Provide and deliver the products and services you request and send you related information, including confirmations and invoices;
Send you communications about products, services, offers, promotions, rewards, and events offered by Glu and other companies, and provide news and information we think will be of interest to you;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Monitor and analyze trends, usage and activities in connection with our Services;
Personalize and improve the Services and provide advertisements, content, suggested connections or features that match user profiles or activities;
Process and deliver contest entries and rewards;
Link or combine with information we get from others to help understand your needs and provide you with better service; and
Carry out any other purpose for which the information was collected.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
With other users of the in connection with the social features of the Services. For example, your username, profile picture and the virtual content you have accumulated in a game may be visible to other users of that game. Additionally, information that you provide in your account registration for a forum and your forum comments may be available to other forum users.
In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Glu or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; or
With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

Analytics, Advertising and Other Services Provided by Other Companies

Security

Glu takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Choices

Website Account Information

You may update, correct or delete your website account information, which includes your username, password, email address and avatar, by logging into your website account and managing your profile. If you wish to delete or deactivate your website account, please email us at privacy[at]glu.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your website account information for a certain period of time.

Cookies

Push Notifications

With your consent, we may send push notifications (or “alerts”) to your mobile device to provide game activity information, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.

Promotional Communications

You may opt out of receiving promotional messages from Glu by following the instructions in those messages or by contacting us at privacy[at]glu.com. If you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

Third Party Analytics and Advertising Services

We have identified the provider names of some of the third-party analytics and advertising services we use. Please see the links below to learn more about the data practices of our third-party service providers (including opt-out mechanisms they may offer):

AdColony: http://privacy.adcolony.com/opt-out
Applovin: https://applovin.com/optout Also see “i” in advertisements provided by Applovin.
Flurry: https://dev.flurry.com/secure/optOut.do
Mobile App Tracking (MAT): https://optoutmobile.com/optOut
Nanigans: http://www.nanigans.com/privacy-policy/
Skillz: You can adjust the collection of geolocation information by adjusting your device’s settings. Please see Skillz’s Terms of Service (http://skillz.com/corporate/terms-and-conditions) and Privacy Policy (http://skillz.com/corporate/privacy-policy) for more information and how to delete your Skillz account.
TapJoy: http://info.tapjoy.com/about-tapjoy/privacy-policy/

Contact Us

If you have any questions about this Privacy Policy, please contact us at: Privacy Policy Administrator. You may also contact our Privacy Policy Administrator by writing to:

***

October, 2009

Glu Mobile Inc. and its subsidiaries and affiliates (collectively, “Glu,” “we,” “our” or “us”) respect the privacy rights of our online visitors and recognize the importance of protecting the information collected about you. We have created this Privacy Policy, which explains what personally identifiable information we collect from you on our web sites (the “Sites”), including without limitation www.glugames.com, www.glu.com, games.glu.com, Glu’s fan page on Facebook (http://www.facebook.com/glumobile), Glu’s fan pages for specific Glu products, Glu’s page on Twitter.com (http://twitter.com/glumobile), and through our mobile and web-based applications and through other means such as Glu newsletters and Glu sweepstakes and contests (the “Services”). This Privacy Policy provides guidance on how we collect, store and use the information you provide through the Services. Please note that this policy does not apply to information collected by or through websites maintained by other companies or organizations to which the Sites may link.

We reserve the right to change this Privacy Policy at any time. Please check this Privacy Policy each time you use the Sites to ensure you are aware of any changes in our privacy practices. Our Privacy Policy will indicate the date it was last updated. We will notify you of any material changes by posting a revised policy on games.glu.com. Your continued use of the Sites will signify your acceptance of the changes to our Privacy Policy.

Glu adheres to the Safe Harbor Principles that were established by the U.S. Department of Commerce in consultation with the European Commission to comply with the European Commission’s Directive on Data Protection that went into effect in October, 1998.

If you have any questions, complaints, or comments regarding our Privacy Policy, please contact our Privacy Policy Administrator. You may also contact our Privacy Policy Administrator by writing to: Privacy Policy Administrator, Glu Mobile Inc., 2207 Bridgepointe Parkway, Suite 300, San Mateo, California 94404.

Third Party Web Sites

The Sites contain links to web sites belonging to third parties not related to Glu. When you leave the Sites, our policies, including this Privacy Policy, no longer govern because Glu cannot control the activities of third parties. Any information you provide to these third parties is subject to their privacy policies, which may differ from ours. Glu is not responsible for the actions of those parties, the content of their web sites, collection or use of information you provide to them, or any products or services they may offer. Our link to a third-party web site does not constitute our sponsorship of, or affiliation with, the third party or the third party’s web site. We encourage you to review and understand the privacy policies of these third parties before providing personal information to them.

Certain products or services displayed on the Sites are provided to you by third party (such as your mobile service provider). The Sites may contain links to web sites operated by third parties that may be of interest to you. Such products shall identify the third parties on the Sites and/or at point of purchase. If you elect to purchase the products, your personal information will be transferred to such third parties and will be subject to their privacy policies. We are not responsible for the privacy policies of such third parties. You should review their privacy policies prior to providing your personal information in connection with such products.

What is Personal Information and When Does Glu Collect It?

Characteristics of Personal Information

When we use the term “personal information” in this Privacy Policy, we are referring to personally identifiable information that specifically identifies an individual (such as an individual’s first and last name, street address, telephone number, e-mail address, credit card or other account number), information about that individual or such individual’s activities or preferences when such information is directly linked to personally identifying information and information that may be used to contact you on-line or off-line. Glu uses your personal information to contact you, complete your transactions (as needed), administer your inquiries and provide the Services.

Personal information does not include “aggregate information,” which is data we use to create aggregate statistics about our customers and visitors, as well as information regarding sales, traffic patterns, and related web site information from which any personal information has been removed. Aggregate information may include demographic information, such as gender, age or city or town of residence, zip code, information about your hardware, software, platform, Internet IP address and connection, and information about your on-line activity including feature usage, game play statistics and scores, user rankings, click paths, on-line profiles (visible to the public or other users of the Sites) and survey responses. We collect aggregate data for a number of purposes, including tracking trends and understanding user needs so that we can better consider new products and services, and improve the quality and value of existing products and services to suit visitor preferences. We use this information to monitor and analyze use of the Services and the Sites, for technical administration, to increase functionality and ease of use and to better tailor the Sites to our visitors’ needs. This policy does not limit or restrict our collection of aggregate information, and we may disclose this information to third parties.

We collect personal information from our visitors during (1) contests and sweepstakes (registration or claiming a prize), (2) during customer support or technical service requests, (3) registration for games or special game-specific event participation, (4) newsletter subscriptions, promotional materials, marketing surveys, email campaigns and other alerts, (5) registration for membership on the Sites, (6) your placement of an order for products or subscriptions from us, (7) your request for services from third party service providers on the Sites or (8) your use of our software or online services. Information collected will vary depending upon the activity and may include your first and last names, e-mail address, home telephone number, mobile telephone number, mobile device type, home address, birth date, and credit card information. Prize winners of contests or sweepstakes may have to provide their Social Security Numbers for tax purposes. We may combine aggregate information and/or demographic information with personal information for the uses described in this Privacy Policy.

We may require personal information to obtain access to some of the Sites; however, where we do not, you may not be able to access certain areas or utilize functions that require registration.

Personal information may also be collected if you provide personal information in connection with interactive features of the Sites or of any mobile or web-based applications, including but not limited to creating a profile, sending a wallpaper image to your phone or inviting a friend. Additionally, information, such as your performance or rank in games (“leaderboards”), or your friends’ member names, may be associated with your member name and displayed on the Sites and in our applications and related services.

Some of our mobile applications may require you to input your mobile telephone number or other personal information into the application. We use this information in connection with providing the application, such as to authenticate you and to communicate with you regarding our services by SMS, text message or other electronic means to your mobile device.

Should you choose to participate in on-line discussions or leave comments on the Sites’ message or bulletin boards, any information you provide in such forums is public information, and there is no expectation of privacy or confidentiality there. Information you provide in these forums is not subject to this Privacy Policy. You should be advised that supplying information in this manner is done at your own risk. Other users of these forums can view, read, collect or otherwise use your posted information for unintended uses including sending you unsolicited e-mail or other messages. We are not responsible for any of the information you choose to submit in these forums.

If you subscribe to the Glu e-mail newsletter, request support, send us an email, or otherwise contact us through the Sites, we collect the personal information that you supply in such communication. We use such information to fulfill and contact you regarding your request and for other purposes as set forth in this Privacy Policy.

On-line submission of resumes, employment applications and the like are not governed by this Privacy Policy.

Automatically Collected Information

As stated above, when you visit the Sites, we may collect information about your computer, such as your IP address, browser type and operating system version. We use this information to help diagnose problems with our server, to administer the Sites, and to improve our products and services. This information may also be used to gather broad demographic information that does not personally identify you.

When you use some of our mobile or web-based applications, your mobile device or personal computer may transmit information about your activities in the application, as well as information you enter in the application, to our servers. We use this information to provide the service to you, to improve our applications and related services, and to gather broad demographic information that does not personally identify you. We may also use the information to learn about and resolve problems with the application, to improve the application and our other products and services, and to develop new products or services. In addition, if any application includes any location-based services, your location may be shared with us while using such feature.

Other Use of Personal Information

In addition to the specific uses mentioned above, we may use the personal information we collect (a) to contact you about your use of the Sites or the Services, such as for administrative purposes or to provide you with customer service; (b) for the purpose for which it was provided, such as to provide our products and services, to fulfill or respond to your requests and to process transactions; (c) to notify you about important changes to our policies, the Sites or our products or services, (d) to alert you regarding new and existing Glu features, products and services, and special Glu offers, promotions and events that we think you may find interesting and for other internal marketing, informational, product development and promotional purposes if you opt-in or request this type of communication from us; (e) to request feedback and to improve the Sites and our product and service offerings, and develop new products and services; and (f) to provide product support.

We may use survey responses to marketing surveys to select and direct advertising for Services that are more likely to be of interest to you. Participation in marketing surveys is entirely optional. We may share aggregate consumer data (which does not contain personal information) with the advertising companies. However, we do not disclose your personal information to our advertisers without your consent, and we do not disclose any personal information about children under 18 years of age who have registered on the Sites to any third parties, regardless of parental consent, or use, share or disclose such personal information other than as set forth in this Privacy Policy.

Finally, we may use your personal information for our internal marketing and demographic studies, so we can consistently improve the Sites to better meet your needs.

Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives.

Opt-In Provision

Generally, we do not share your personal information with third parties, except as described by this Privacy Policy. However, if we intend to share such information with more third parties, we will ask you to opt-in or consent to sharing your personal information with parties outside of Glu (except to the extent required by law, court order, or as requested by other government or law enforcement authority) when we first collect information about you. In addition, if you do not want us to send you e-mail or postal mail about our products and services, you can choose not to opt-in at the time of registration or information collection. If, at a later date, you choose to have your name removed from our mailing list, you can do so by unsubscribing as directed in the newsletter, or by contacting our Privacy Policy Administrator. You may also click the unsubscribe link on our email offers and newsletters.

How We Protect Your Information

We have put reasonable security measures in place to prevent the loss, misuse, destruction and alteration of information under our control. For example, when you access your account information, we use the Secure Socket Layer (SSL) protocol to encrypt information you input before it is sent to us.

Our Disclosure of Personal Information

Except as described in this Privacy Policy, we will not share your personal information with third parties unless you have consented to the disclosure or we believe the disclosure is appropriate to: (1) comply with the law or with legal process, (2) protect and defend our rights and property, such as to determine, bill and collect for amounts owed to us, (3) protect our customers or users, including from misuse or unauthorized use of the Sites or our services, or (4) protect the safety or property of our employees, customers, users or others. We may disclose or transfer your personal information (1) to our corporate affiliates (for example, subsidiaries or parent corporation), (2) to our service providers (like fulfillment, hosting, or payment service providers), but only for their use to provide the requested service to you, (3) to an acquirer in connection with the sale or other transfer of the business or assets of Glu, or (4) where you provide your express consent to the disclosure. We will require our corporate affiliates and service providers that receive your personal information to limit their use and disclosure of your information to the purposes for which you provided it.

We may employ third party companies and individuals to provide and/or facilitate our Services, to perform tasks, such as sending out newsletters and/or process billing transactions, or to assist us in analyzing how the Sites and Services are being used. These tasks necessarily require that we share your personal information with such third parties. We require that they adhere to this Privacy Policy and protect the confidentiality of your personal information, and they are prohibited from using your personal information for any other purposes without your consent.

Cookies

We use “cookies,” which are small pieces of information that are stored by your browser on your computer’s hard drive, and other technologies, to passively collect demographic information, personalize your experience on the Sites and monitor advertisements to track your purchases, the pages you have viewed, the games you have played and other activities. Our cookies do not contain any personally identifiable information and are used to either identify you as a returning customer or improve the experience on the Sites. Third parties that place advertising banners or other content on the Sites may also use cookies. Cookies received with ads collect information on behalf of the advertising companies, and we do not have access to this information. We are not responsible for the information collected by these third parties’ cookies or the use by such third parties of the information they collect. Most browsers are set up to accept cookies, but you can adjust your browser settings to disable cookies or alert you when cookies are being delivered. Disabling cookies may prevent web sites from functioning as intended.

We may also maintain log files which contain IP addresses. An IP address is a numeric address that is assigned to your computer by your Internet Service Provider. In general, we only use log files to monitor traffic on the Sites, to report aggregate information to our advertisers and to troubleshoot technical problems. In the event of user abuse of the Sites, however, we may block certain IP addresses or console IDs provided by our licensed hardware manufacturers. IP addresses and console IDs may be used to personally identify you in order to enforce our Terms of Use.

A Special Note About Children

We urge parents to instruct their children to never give out their real names, addresses or phone numbers, without permission, when using the Internet. We recognize a special obligation to protect personal information obtained from young children. Therefore, with respect to children residing in certain jurisdictions, no information should be submitted by children 12 years of age or under. In order for children 12 years of age and under in such jurisdictions to participate in online activities that require registration, we require prior written permission or other verifiable consent from a parent or guardian. In other jurisdictions, prior written permission or other verifiable consent may be required from a parent or guardian for children 18 years of age and under. Upon registration, the appropriate permission form will be made available. This form must be signed by the child’s parent or guardian and returned to Glu by mail to the Privacy Policy Administrator.

If for any reason you are concerned that your child’s personally information maintained by us is not correct or complete, you wish to have your child’s personal information deleted from our records, or you want us to discontinue further collection or use of your child’s personal information, please contact our Privacy Policy Administrator who will be happy to review, update or remove your child’s information as appropriate.

Where We Store Information

Glu is a global organization and many of the computer systems on which we collect, store and use the information we collect or receive are based in North America, Asia, Europe, Latin America and elsewhere. Your personal information may be transferred to, used, processed or held by us in these and in other countries, including countries both in and outside the European Union, and used for the purposes set out in this Privacy Policy.

Reviewing and Correcting Your Information, Requesting Removal from Mailing Lists and Deactivating Your Account

If for any reason you are concerned that the personal information maintained by Glu is not correct, or should you wish to have your account(s) deactivated or be removed from our mailing list, please email the Privacy Policy Administrator. We will be happy to review, update or remove information as appropriate. We may still retain your information in our files, however, to resolve disputes, enforce our user agreement, and due to technical and legal requirements and constraints related to the security, integrity and operation of the Sites.

By using the Sites, you signify your assent to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.

How to Contact Us

We welcome your questions and comments about privacy. Please send your feedback to our Privacy Policy Administrator.