DATE LAST MODIFIED: 24 February 2025
At CARTERS INC (“we”, “us” or “our”), we take your privacy and the security of
your information very seriously. This Privacy Policy (“Privacy Policy”) sets out how we
collect and process information that identifies you or is associated with you (your
“personal information”) when you access our Site or play a game (a “Developer Game”)
that is authorized by the independent game developer MOMA TECH LIMITED to be published
by us. In addition, CARTERS INC, together with MOMA TECH LIMITED, will jointly provide
you with legal services.
1)Information We Collect
Personal Information you provide directly in the Developer Game: We may collect
the following personal information that you input when you play a Developer Game:
a) contact details such as your first name and surname, email address,
residential address and mobile or other phone numbers;
b) personal information such as gender, age, age range or your image; account
login details, including your username, password and pictures associated with your
profile;
c) information sent bilaterally or within a small group using email, post or
other methods of communication;
d) information we obtain from a third party, such as a site or platform
provider, about your use of or interest in our services;
f) location information including location information provided by a mobile or
other device interacting with one of our websites, or associated with your IP address,
where we are permitted by law to process this information;
g) activity, technical and device information about your use of our websites,
such as the content you view, the time and duration of your visit on our websites, how
often you use our services, how you first heard about our websites, your preferences and
information about your interaction with the content offered through our websites, your
hardware model, device type, other unique device identifiers, operating system version,
browser type and IP address;
h) government identifiers such as passport, driver's license, social security
numbers where we are required to do so for tax or other legal reasons; and
i) sensitive information such as biometric data, geolocation, drivers licenses
and financial information to comply with our legal and regulatory purposes.
2)How We Collect Information
We use personal information we collect to:
Register and authenticate you: we use your personal information to allow you to
register for and access Developer Games and update your profile information.
Ensure you are able to play a Developer Game: we use your personal information
to ensure that you are legally able to access and play a Developer Game, or use certain
features and functionalities of a Developer Game, in your country or state.
Help you find other players on Developer Games, such as people whose details are
saved in your phone contacts.
Process your payments and purchases, such as updating your account to reflect
any purchases that you make in a Developer Game.
Provide features and functionalities of the Developer Game, such as in-app
messaging, chat, gameplay performance records and profile customization features.
Provide support in relation to Developer Games.
Monitor the performance of and improve our Services: we use your personal
information to measure the performance of our Services, fix issues, improve and
otherwise develop the features and functionalities of our Services. We also use your
personal information to test and develop new products and services.
Identify how you learned about a Developer Game in order to understand the
effectiveness of any advertising of Developer Games.
Communicate with you and deal with complaints: we use your personal information
to send you communications relating to our Services and to address any comments or
complaints you submit to us.
Send you service related communications, such as purchase confirmations.
Send you marketing materials, including emails, newsletters, and other marketing
communications in accordance with your preferences.
Inform and support our marketing, including helping us determine products and
services that may be of interest to you and contacting individuals about our Services.
Maintain the safety and security of our Services: we use your personal
information to detect and prevent fraud, abuse or other harmful activities, diagnose and
fix technology problems, conduct security investigations and risk assessments, and
improve and enforce our security measures.
Legal and regulatory requirements and proceedings: we use your personal
information in connection with legal and regulatory proceedings and requirements,
including the defense of legal claims, compliance with corporate reporting obligations,
and compliance with applicable laws.
Enforce our rights: we may use your personal information to monitor,
investigate, prevent and/or mitigate violations of our terms of use as well as enforce
our agreements with third parties and business partners.
For any other lawful purpose, or other purpose that you consent to.
We may transfer personal information to third parties for the purpose of providing the
Services. We may disclose personal information to our appropriate affiliates, including
third-party service providers, to provide you with the Services. These third-party
service providers are not authorized to retain, share, store or use the personal
information for any purposes other than to provide the services they have been hired to
provide.
1）We may share information with third parties in the following cases:
a.Required by law.
b.The team faces mergers, acquisitions, changes in control, etc. of other
companies.
c.We may share your information with certain third-party companies, such as
advertising platforms, and we will require these third parties to (i) ensure the
security of the data, (ii) never use the data for purposes other than providing services
to us purpose, and (iii) use the data only in accordance with the Privacy Policy.
In any case other than those set forth above, we will not share your personally
identifiable information with third parties without your prior consent.
2）Information Security and Data Rights
We are committed to protecting the security of your personal information. We use
a variety of security technologies and procedures to help protect your personal
information from unauthorized access, use or disclosure. We only retain your personal
information for as long as necessary, and under no circumstances, do we collect personal
information through our software and services. We will retain information we collect in
accordance with this Privacy Policy to fulfill our business and/or operational purposes
or to comply with legal requirements. We have implemented safeguard procedures to
protect your information in accordance with industry standards, and we have restricted
access to your information on servers, which are encrypted.
However, since the Internet is not a 100% secure environment, we cannot
guarantee that the information you deliver to us is 100% secure. After you uninstall a
software or stop using our services, we will delete all your data within three months.
If you click to clear your data through internal software, we will immediately delete
your data saved locally, and delete all your data on the server within one month.
If you do not want us to use the information we collect to serve you advertisements, you
can opt out of receiving such advertisements.
Please note: (a) if you opt out, we may still collect some data about your
online activities for operational purposes (such as fraud prevention), but it will not
be used by us for the purpose of advertising to you; (b) if you use multiple browsers or
devices, on each of which you may need to perform this opt-out; and (c) other
advertising companies' opt-out features may differ from ours, and we have no control
over the practices of any third parties. We make no representations or warranties
regarding such opt-out services. These services are independent of us, and we have no
control over, and are not responsible for, their performance.
We pay close attention to the protection of our intellectual property. The selection and
arrangement of all content, images, design, graphics, text, logos, buttons, interfaces,
icons, audio and video clips, and software and services are our exclusive property and
are subject to the Berne Convention, international copyright laws and other applicable
laws and legal protection.
You agree to use the Software and Services only for lawful purposes. We may,
without liability to you, for any conduct that we believe violates any applicable law or
this Privacy Policy, or is harmful to the interests of other users, third parties,
sponsors, licensors, service providers, merchants, Terminate your access or suspend
access to all or any portion of the Software and Services without notice.
We do not want you to send us any confidential or proprietary information,
whether by email or otherwise. Any information, materials, suggestions, ideas or
comments sent to us will be considered non-confidential and by submitting such
information to us, you give us the absolute right to use, modify, reproduce, transmit,
display and distribute such information , without payment or other compensation to you.
However, we will not use your name unless we are required by law to identify the source
of the material, information, advice, ideas or opinions, or we first obtain your
permission.
We respect the privacy of children. The Services are not intended or directed towards children or minors under the age of 18. Please do not use the Services if you are under the age of 18. We are intent on complying with applicable laws and regulations regarding minors, including the United States’ Children’s Online Privacy Protection Act. Specifically, We do not knowingly solicit or collect personal information from individuals under 18. If we learn that any personal information has been collected inadvertently from a child, we will delete the information as soon as possible.
1)CALIFORNIA PRIVACY
These additional California Privacy Disclosures (the “CA Disclosures”)
supplement the information contained in our Privacy Policy and apply solely to
individual residents of the State of California (“consumers” or “you”). These CA
Disclosures provide additional information about how we collect, use, disclose and
otherwise process personal information of individual residents of the State of
California, either online or offline, within the scope of the California Consumer
Privacy Act of 2018 (“CCPA”). Unless otherwise expressly stated, all terms in these CA
Disclosures have the same meaning as defined in our Privacy Policy or as otherwise
defined in the CCPA. For purposes of these CA Disclosures, “personal information” has
the meaning provided by the CCPA and does not include information that is publicly
available, that is deidentified or aggregated such that it is not capable of being
associated with us, or that is excluded from the CCPA’s scope. This section does not
apply to information relating to our employees, contractors, and other personnel.
As a California resident, you may be able to exercise the following rights
(subject to certain limitations at law):
· The Right to Know any or all of the following information relating to your
personal information we have collected and disclosed in the last 12 months, upon
verification of your identity:
· The specific pieces of personal information we have collected about you;
· The categories of personal information we have collected about you;
· The categories of sources of the personal information;
· The categories of personal information that we have disclosed to third parties
for a business purpose, and the categories of recipients to whom this information was
disclosed;
· The categories of personal information we have sold and the categories of
third parties to whom the information was sold; and
· The business or commercial purposes for collecting or selling the personal
information.
· The Right to Request Deletion of personal information we have collected from
you, subject to certain exceptions (please note that we may be unable to provide you
with access to our services if you choose to delete certain personal information, but we
will always let you know if that is the case).
· The Right to Opt Out of Personal Information Sales to third parties now or in
the future.
2)EUROPEAN PRIVACY
These European Privacy Disclosures supplement the information contained in our
Privacy Policy, and apply to our processing of your personal information where you are
based in the EEA. For the purposes of EEA data protection laws, We are the controller of
the personal information that we receive from you as described in this Privacy Policy.
This means that we are responsible for, and control the processing of this personal
information. The following tables set out further detail about the categories of
personal information we collect about you and how we use that personal information, as
well as the legal basis which we rely on to process the personal information and
recipients of that data. We will indicate to you where the provision of certain personal
information is required in order for us to provide you certain features of our Services.
If you choose not to provide such personal information, we may not be able to provide
those parts of our Services to you or respond to your other requests.
· You have the right to withdraw consent at any time where we are relying on
consent to process your personal information. However, this will not affect the
lawfulness of any processing carried out before you withdraw your consent.If you
withdraw your consent, we may not be able to provide the Services to you. We will advise
you if this is the case at the time you withdraw your consent.
· You have the right to request access to your personal information (commonly
known as a “data subject access request”). This enables you to receive a copy of the
personal information we hold about you and to check that we are lawfully processing it.
· You have the right to request correction of the personal information that we
hold about you. This enables you to have any incomplete or inaccurate personal
information we hold about you corrected, though we may need to verify the accuracy of
the new information you provide to us.
· You have the right to request erasure of your personal information. This
enables you to ask us to delete or remove personal information where there is no good
reason for us continuing to process it.You also have the right to ask us to delete or
remove your personal information where you have successfully exercised your right to
object to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal information to comply with
local law. Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable, at the
time of your request.
· You have the right to object to processing of your personal information where
we are relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to processing
on this ground as you feel it impacts on your fundamental rights and freedoms.You also
have the right to object where we are processing your personal information for direct
marketing purposes. In some cases, we may demonstrate that we have compelling legitimate
grounds to process your information which override your rights and freedoms.
· You have the right to request restriction of processing of your personal
information. This enables you to ask us to suspend the processing of your personal
information in the following scenarios:
if you want us to establish the accuracy of the personal information;
where our use of the personal information is unlawful but you do not want us to
erase it;
where you need us to hold the personal information even if we no longer require
it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your personal information but we need to verify
whether we have overriding legitimate grounds to use it.
· You have the right to request the transfer of your personal information to you
or to a third party. We will provide to you, or a third party you have chosen, your
personal information in a structured, commonly used, machine-readable format.Note that
this right only applies to automated information which you initially provided consent
for us to use or where we used the information to perform a contract with you.