Privacy Policy

EFFECTIVE DATE: November 8, 2017

1. INTRODUCTION AND PURPOSE

Second Entity LLC, a California limited liability company (“Second Entity”, “we”, “us”, “our”) is committed to respecting the privacy rights of its customers, visitors, and other users of our websites, our downloadable mobile applications, or other software you download or use, and any services we provide you (collectively, along with any user guides, specifications, and other related documentation, the “Software”). We created this Privacy Policy to give you confidence as you download and use the Software, and to demonstrate our commitment to fair information practices and the protection of personal information. This Privacy Policy is part of our End User License Agreement www.secondentity.com/eula

This Privacy Policy is only between Second Entity and you, as an individual - or, for entities, any employee, agent, or representative you authorize to use the Software (collectively, “you”, “your”, “user”) and is only applicable to the Software.

2. OUR THIRD-PARTY PARTNERS

We use third-party partners services and applications in the Software, and if you use any other websites, apps, ISP or other services, or store to access or download the Software, or that is linked from or otherwise accessible from the Software, you are subject to the data collection, storage, and use practices and policies of these third parties that may differ materially from this Privacy Policy and are covered by these third parties’ respective privacy policies. Third-party partners you may encounter in the Software include those listed in Section 6, below.

3. TYPES OF INFORMATION COLLECTED

(a) Traffic Data Collected. We may automatically track and collect the following types of information when you download or use our Software: (1) Site or store of download and related information such as what days/times downloads occurred; (2) IP addresses and geolocation data; (3) domain servers; (4) types of devices accessing the Software; and (5) types of web browsers used to access the Software (collectively, along with any similar information that does not individually identify you, “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for our research, development, and marketing purposes, or for improving your and other users’ experience with the Software. We may use “cookies” and other technologies such as pixel tags, local shared objects, hardware-based identifiers, clear GIFs, and web beacons to customize content specific to your interests, to ensure that you see customized advertising, and for other similar purposes and for administrative purposes. We may also use device identifiers to create anonymous guest accounts and store Software settings, preferences, game progress, and the like.

(b) Personal Information Collected. In order for you to access or use certain features of the Software, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information, as well as other similar information that you choose to provide to us, and may be provided by you to us directly or through a third party you have authorized to do so, such as Facebook: (1) Contact Data (such as your name, address, e-mail address, telephone number, and social media profiles, user names, and friends); (2) Financial Data (such as your Second Entity and Paypal account information and credit card and debit card numbers and related billing and payments information); and (3) Demographic Data (such as your age, geographic location, and interests). If you create an account with us or otherwise communicate with us through our Software, by e-mail, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, or contact us offline by phone or mail, we may collect any information provided in such communications as Personal Information. If these are public or available to other users, then we have no control over any information posted to such a public forum, and you should exercise caution in revealing Personal Information in public forums, including social media.

(c) Do Not Track Requests. Your use of a do-not-track setting will not affect any of the information collection practices stated in subsections (a) and (b), above. Our third-party partners, such as advertising companies that track users over time and across multiple websites, may or may not honor your do-not-track requests.

4. CHILDREN’S PRIVACY AND COPPA COMPLIANCE

In compliance with the Children’s Online Privacy Protection Act (“COPPA”), the Software is not directed to children - and we do not knowingly collect any Personal Information from users - under the age of 13. Children under age 13 are also prohibited from using the Software in accordance with Section 1 of our End User License Agreement. Additionally, for those users 13 to 17 years old, or who have not reached the age of legal majority in your jurisdiction, your parent or guardian must review and assist with your privacy choices under this policy. If you are the parent or guardian of a child under the age of 13 who has provided us with Personal Information, please contact us at so that we may purge such information from our systems.

5. OUR USE OF INFORMATION COLLECTED

We may use Contact Data and Traffic Data to provide and improve the Software, to send you information about our company or our products or services, or promotional material from some of our partners, or to contact you when necessary. We may use your Financial Data primarily to verify your identity and to bill and collect payment from you for the Software. We may use your Demographic Data to customize your Software experience, such as by displaying content that we think you might be interested in and according to your preferences, and to research and improve the Software.

6. OUR DISCLOSURE OF INFORMATION TO THIRD PARTIES

We share certain categories of information we collect from you in the ways described in this Privacy Policy. The companies named below are for illustrative purposes, and we may or not have an active relationship with or provide information to these third parties at any given time. Except as expressly stated below, we are not affiliated with any of these parties.

(a) Personal Information. We may share your Personal Information with one or more of the following categories of third parties:

Select technology companies and other services providers that enable us to deliver and provide the Software, such as PlayFab. These business partners have all agreed to uphold the same or similar standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to Second Entity.
Other users; however, such sharing is limited to your name, user name, avatar, friends list, and game scores or results, unless you grant us permission to share additional information.
Publicly, including on social media, but only at your specific request.

(b) Other Information. Additionally, we may share Traffic Data and aggregated, non-personally identifiable Demographic Data with one or more of the following categories of third parties:

Analytics providers such as Unity Analytics and Google Analytics.
Advertising and marketing companies such as Unity Ads and Heyzap.
We share Demographic Data with advertisers and other third parties only on an aggregate (non-personally-identifiable) basis.

(c) Opting Out. If you do not want us to share your Contact Data with any third parties, please follow the relevant opt-out instructions (if any). Opting out may not be possible in all instances; if you are unable to locate the opt-out procedure, or have questions concerning your opt-out options, please contact us at An opt-out request will likely limit your ability to take advantage of all of the features of the Software and does not mean you will never see any advertising. In addition, we maintain a procedure for you to review and request changes to your Personal Information, that is described in Section 9, below.

Regardless of any opt-out, we may also share your Traffic Data and Personal Information with potential or actual lenders or purchasers on or of all or part of the Software or Second Entity, as reasonably necessary to facilitate such a transaction.

You may choose not to provide us with any Personal Information. In such an event, you can still access and use some of the Software such as our websites; however you will not be able to access and use those portions of the Software that require your Personal Information. If you do not wish to receive information and promotional material from us or from some of our partners, you may select the appropriate “opt-out” option (if provided) each time we ask you for Personal Information.

7. CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION

We follow generally accepted industry standards to protect your Personal Information. However, no method of transmission over the Internet or method of electronic storage is 100% secure or failsafe. Therefore, while we strive to use commercially reasonable means to protect personal information, we cannot and do not guarantee absolute security. We are not responsible for the unauthorized acts of others and assume no liability for any disclosure of information due to errors in transmission, unauthorized third-party access (such as through hacking or theft of computers) or other acts or omissions of third parties, or for acts or omissions beyond our reasonable control.

Except as otherwise provided in this Privacy Policy, we will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process, or assist in a law enforcement or government investigation; (b) protect our rights or property; or (c) enforce our Privacy Policy or End User License Agreement. Your Personal Information is stored on secure servers that are not accessible by third parties. We provide you with the capability to transmit your Personal Information via secured and encrypted channels if you use a similarly equipped web browser and device.

8. LOST OR STOLEN INFORMATION

You must promptly notify us if your credit or debit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit or debit card number, user name, or password from your account and update our records accordingly.

9. ACCESSING, UPDATING, AND CORRECTING PERSONAL INFORMATION

We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may visit your personal profile in the Software or, if none is available, then contact us at Through your personal profile (if provided, and otherwise, by email) you may: (a) review and update your Personal Information that we have already collected; (b) choose whether or not you wish us to send you information about our company, or promotional material from some of our partners; and/or (c) choose whether or not you wish for us to share your Personal Information with certain third parties.

10. YOUR CALIFORNIA PRIVACY RIGHTS

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once each calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately preceding calendar year.

To obtain this information, please send an e-mail message to with “Request for California Privacy Information” in the subject line. We will provide in response the requested information to you at your e-mail address.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only required information will be included in our response.

11. UPDATES AND CHANGES TO PRIVACY POLICY

We may amend this Privacy Policy from time to time by posting a new version to our website, when providing an update, or providing any other reasonable notification to you. We will update the effective date of this Agreement, and it is your responsibility to check for updates periodically.