This is Dave Sapien ltd’s Privacy Policy. It was last updated on August 31st, 2013.

1. Introduction: Please read the following to learn more about the Dave Sapien ltd Privacy Policy. The Dave Sapien ltd website (www.DaveSapien.com) is intended for use by parents and Dave Sapien ltd’s various related games, applications, features, content, widgets or services (collectively with the website, the “Service”) are unless otherwise stated intended for use by the whole family including young children with parental participation and supervision. Dave Sapien ltd recognizes the importance of protecting any information collected from the users (each a “User” or collectively, “Users”) of its Service, and has adopted this Privacy Policy to inform its Users about the types of information Dave Sapien ltd gathers about a User online while using Dave Sapien ltd’s Service, how Dave Sapien ltd may use that information, whether Dave Sapien ltd discloses it to anyone, and the choices a User has regarding use of and correction of the information.

THIS PRIVACY POLICY IS PART OF THE TERMS OF SERVICE  WHICH YOU, OR IF YOU HAVE NOT REACHED THE AGE OF MAJORITY IN YOUR JURISDICTION, A PARENT OR LEGAL GUARDIAN, MUST READ AND ACCEPT ON YOUR BEHALF.

Contact us at privacy@davesapien.com concerning anything you do not understand.

IF YOU, OR YOUR PARENT/GUARDIAN ON YOUR BEHALF, DO NOT WISH TO BE BOUND BY THE TERMS OF SERVICE, INCLUDING THIS PRIVACY POLICY, PLEASE EXIT THE SERVICE NOW AND DO NOT DOWNLOAD, ACCESS OR USE Dave Sapien ltd’s SERVICES.

1. Effective Date: The Privacy Policy detailed herein applies to any and all information that a User may have obtained from or provided to Dave Sapien ltd. Dave Sapien ltd reserves the right, at its full and complete discretion and without prior notice, to change, modify, amend, add, subtract, or otherwise remove portions of its Privacy Policy at any time and for any or no reason. Although Dave Sapien ltd may attempt to email Users a copy of the revised Privacy Policy at the email address on file, if any, please periodically continue to check the Privacy Policy at www.DaveSapien.com/privacy for any changes. Such modifications will apply to disputes arising under the Privacy Policy from the date of posting forward.  A User’s use of the Service after the posting of any amendments, deletions or other changes to the Privacy Policy will constitute acceptance, acknowledgment and agreement to the respective changes.  If any such modification requires Dave Sapien ltd to provide notice to a parent or receive parental consent, Dave Sapien ltd will take the steps necessary to comply with those requirements at that time.

2. Types of Data:  For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies a User as an individual.  “Non-personal data” means information that does not directly identify a User. Additionally, non-personal data means “aggregate” and “de-personalized” information, which is data Dave Sapien ltd collects about the use of the Dave Sapien ltd Service, from which any personally identifiable data has been removed.

3.  Information You Provide to Dave Sapien ltd: A User may make personal data available to Dave Sapien ltd such as, for example: (i) when a parent subscribes to a newsletter or alerts through the parent section of the Service; (ii) when a parent contributes user generated content to the Service or participates in any support forums, community blogs or the like that Dave Sapien ltd may establish; (iii) when a User requests technical support; or (iv) otherwise through use of the Dave Sapien ltd Service where personal data is required for use and/or participation.  The types of personal data collected may vary depending on the type of activity the User is engaged in. The personal data Dave Sapien ltd may collect, process and use may include, but are not limited to the User’s name, screen/nick name, Dave Sapien ltd or third party service ID, e-mail address, photo or other image, birthdate, gender, or avatar image.

4.  Other Information Dave Sapien ltd Collects and Uses:  Dave Sapien ltd may use tools or third party analytical software to automatically collect and use certain data including, but not limited to: (i) device properties, including, but not limited to IP address, Media Access Control (“MAC”) address and unique device identifier or other persistent or non-persistent device identifier (“Device ID”); (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) game progress, time used playing, score and achievements; (v) other non-personal data as reasonably required by Dave Sapien ltd to enhance the Service and other Dave Sapien ltd products and services.

5.  Use and Sharing of Personal and Non-Personal Data: Dave Sapien ltd may use personal and non-personal data, and disclose personal and non-personal data, in accordance with applicable legislation and this Privacy Policy. Additionally, Dave Sapien ltd may disclose personal data to its parent company and its subsidiaries in accordance with this Privacy Policy. Dave Sapien ltd may disclose personal and non-personal data to its partners and contractors for purposes of analyzing usage of the Service, providing customer and technical support, managing and providing the Service (including managing advertisement serving, where and how permitted by law), customizing Dave Sapien ltd’s communications, and to further develop the Service and other Dave Sapien ltd services and products.  When Dave Sapien ltd shares this information, it is with vendors and other service providers who are engaged by or working with Dave Sapien ltd in connection with the operation of the services Dave Sapien ltd provides to the User and/or for analytics purposes which may require the reproduction and display of such information in an aggregated and anonymized manner such that will not in any way identify the User. Dave Sapien ltd may use a parent’s personal data provided in the parent section to send messages to the parent with informative and/or commercial content about Dave Sapien ltd’s services or third party products and services Dave Sapien ltd thinks may be of interest to the User, such as new features and services, special offers and updated information.  In addition, if a User has agreed to receive push notifications, and appropriate consent to receive them has been given, Dave Sapien ltd will use the data collected and share it with its vendors for the purpose of delivering approved push notifications. If a User contacts Dave Sapien ltd by email, Dave Sapien ltd will use the personally identifiable email address information only to respond to the specific inquiry. The Service may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. Dave Sapien ltd treats information collected by cookies and similar technologies as non-personal data. Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user’s computer. Dave Sapien ltd’s cookies do not include personal data and are typically used to quickly identify a User’s device and to “remember” the User. Users can disable cookies or set their browsers to alert them when cookies are being sent to their device; however, disabling cookies may affect their ability to use the Service. Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image that allows Dave Sapien ltd to count Users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications Dave Sapien ltd sends to a User may contain pixel tags that enable Dave Sapien ltd to track a User’s usage of the communication, including whether the communication was opened and/or what links were followed, if any. From time to time, Dave Sapien ltd may hire agents and contractors to collect and process personal data on Dave Sapien ltd’s behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Dave Sapien ltd. These agents and contractors may not use a User’s personal data for their own marketing purposes. Dave Sapien ltd may use third party service providers such as credit card processors, e-mail service providers, shipping agents, data analyzers and business intelligence providers. Dave Sapien ltd has the right to share Users’ personal data as necessary for the aforementioned third parties to provide their services for Dave Sapien ltd. Dave Sapien ltd is not liable for the acts and omissions of these third parties, except as required by law. Dave Sapien ltd may disclose a User’s personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose a User or Dave Sapien ltd to legal liability. Dave Sapien ltd may also disclose a User’s personal data to third parties when Dave Sapien ltd has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Dave Sapien ltd’s rights, property, operations, Users or others who may be harmed or may suffer loss or damage, or Dave Sapien ltd believes that such disclosure is necessary to protect Dave Sapien ltd’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Dave Sapien ltd. To the extent permitted by applicable law, Dave Sapien ltd will make reasonable efforts to notify affected Users of such disclosure through Dave Sapien ltd’s website or in another reasonable manner. Dave Sapien ltd may store and/or transfer User personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy. Dave Sapien ltd may disclose User personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of Dave Sapien ltd’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data. When a parent discloses data about him or herself in the course of contributing user generated content or participating in support forums, community blogs or the like, the information disclosed is public information, and there is no expectation of privacy or confidentiality. Dave Sapien ltd is not responsible for any personal data a User makes public in any of these forums.

6. Third Party Terms and Conditions: A User’s access to and use of the Service may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services and payment providers. Dave Sapien ltd is not liable for any such third party terms and conditions and their use of Users’ personal data. Dave Sapien ltd may in its discretion make available links through advertisements or otherwise enable Users to access third party products or services. Dave Sapien ltd is not responsible for the actions of such third parties, the content of their products or services, the use of information a User provides to them, or any products or services they may offer. Dave Sapien ltd’s linking to those products or services does not constitute its sponsorship of, or affiliation with, such third parties.

7. Data Retention and Accuracy: Dave Sapien ltd retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Dave Sapien ltd deletes all aforementioned data in its possession within a reasonable timeframe. Dave Sapien ltd does not verify the accuracy of personal data. Dave Sapien ltd may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Dave Sapien ltd user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Service.

8. Security: Dave Sapien ltd follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Dave Sapien ltd’s possession. Only those persons with a need to process Users’ personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to Users’ personal data in Dave Sapien ltd’s possession. Personal data collected by Dave Sapien ltd is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, Dave Sapien ltd maintains data within a fire-wall protected environment. While Dave Sapien ltd exercises reasonable care and due diligence in providing a secure conduit of information between a User’s computer or other device and its servers, Dave Sapien ltd cannot and does not guarantee the security of materials or information transmitted to Dave Sapien ltd or other Users over the Internet or wirelessly. Therefore, while Dave Sapien ltd will attempt to protect the transmission of any information using methods which comply with the industry standards, Dave Sapien ltd does not accept liability for any unintentional disclosure of same.

9. Further Information: Users that wish to opt-out from receiving communications (such as any newsletters or offers) from Dave Sapien ltd, should contact privacy@DaveSapien.com. Dave Sapien ltd makes good faith efforts to enable Users to review, update or correct any personal data in Dave Sapien ltd’s possession. Users should contact Dave Sapien ltd at privacy@DaveSapien.com. Dave Sapien ltd will need sufficient information from the User to establish the User’s identity and to verify the User’s access, and also to assist in handling the User’s request. Even if personal data is changed or deleted according to a User request, Dave Sapien ltd may still retain some of User personal data to resolve disputes, enforce Dave Sapien ltd user agreement(s), and comply with technical and legal requirements and constraints related to the integrity, security and operation of Dave Sapien ltd Services.