Please read this policy carefully to understand how we handle and treat your personal information.
What information do we collect?
We may collect and process the following personal information from you:
Information you provide to us: We collect personal information when you voluntarily provide us with such information in the course of using our website or Services. We also collect personal information from you when you subscribe to our newsletter, or respond to a survey. If you make an enquiry through our website, or contact us in any other way, we will keep a copy of your communications with us.
Information we collect when you do business with us: We may process your personal information when you do business with us – for example, as a customer or prospective customer, or as a vendor, supplier, consultant or other third party. For example, we may hold your business contact information and financial account information (if any) and other communications you have with us for the purposes of maintaining our business relations with you.
Information we automatically collect:We may also collect certain technical information by automatic means when you visit our website, such as IP address, browser type and operating system, referring URLs, your use of our website, and other clickstream data. We collect this information automatically through the use of various technologies, such as cookies.
Personal information where we act as a data processor:We also process personal information on behalf of our customers in the context of supporting our products and services. Where a customer subscribes to our Services for their website, game or app, they will be the ones who control what event data is collected and stored on our systems. For example, they may ask us to log basic user data (e.g. email address or username), device identifiers, IP addresses, event type, and related source code. In such cases, we are data processors acting in accordance with the instructions of our customers. You will need to refer to the privacy policies of our customers to find out more about how such information is handled by them.
What do we use your information for?
The personal information we collect from you may be used in one of the following ways:
To deal with your inquiries and requests
To provide you with technical support (your information helps us to better respond to your individual needs)
To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you), including to improve the navigation and content of our sites
For website and system administration and security
For general business purposes, including to improve customer service (your information helps us to more effectively respond to your customer service requests and support needs), to help us improve the content and functionality of our Services, to better understand our users, to protect against wrongdoing, to enforce our Terms of Service, and to generally manage our business
To process transactions and to provide Services to our customers and end-users
For recruitment purposes, where you apply for a job with us
To administer a contest, promotion, survey, or other site features
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.
Yes. Cookies are small files that a site or its service provider transfers to your computers hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. You can find information on popular browsers and how to adjust your cookie preferences at the following websites:
Do we disclose any information to outside parties?
We will only share your information with third parties in certain circumstances:
In the event of a corporate sale, merger, reorganization, dissolution or similar event, your personal information may be sold, disposed of, transferred or otherwise disclosed as part of that transaction.
We may also disclose information about you to third parties where we believe it necessary or appropriate under law, for example: (1) to protect or defend our rights, interests or property or that of third parties; (2) to comply with legal process, judicial orders or subpoenas; (3) to respond to requests from public or government authorities, including for national security and law enforcement purposes; (4) to prevent or investigate possible wrongdoing in connection with the Services or to enforce our Terms of Service; (5) to protect the vital interests of our users, customers and other third parties.
We may use and share aggregated non-personal information with third parties for marketing, advertising and analytics purposes.
We do not sell or trade your personal information to third parties.
Third Party Links
Occasionally, at our discretion, we may include or offer third party products or services on our website. If you access other websites using the links provided, the operators of these websites may collect information from you that will be used by them in accordance with their privacy policies. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
EU-US Privacy Shield
To access the Privacy Shield List and to find details of our certification, please visit: https://www.privacyshield.gov/
Functional Software, Inc is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regards to our compliance with the Privacy Shield.
Residents of the European Union who believe that their information has not been processed in compliance with the Privacy Shield Principles may raise their complaint in a number of ways:
(1) You can contact us directly using the contact details provided below and we will respond to your complaint within 45 days of receipt:
(2) We have further committed to cooperate and comply with the panel of the European data protection authorities (DPAs) as our independent recourse mechanism in the resolution of your Privacy Shield complaint. If you are unsatisfied with the response you have received from us, or your complaint remains unresolved, you can contact your local DPA (contact details available here), and they will investigate your complaint free of charge.
(3) Further, your complaint may be referred to the US Department of Commerce or the FTC for further investigation;
(4) If your complaint is not resolved through the above methods, a binding arbitration process may be available under the Privacy Shield in certain circumstances. To find out more about the Privacy Shield's binding arbitration scheme, please see this article.
If we have received your personal information in the US under the Privacy Shield, and subsequently transfer that information to a third party agent or service provider for processing, we will be responsible if our third party agent or service provider fails to process your personal information in compliance with the Privacy Shield Principles and this causes you harm.
If you are from the EU, you may have the right to access a copy of the personal information we hold about you, or to request the correction, amendment or deletion of such information where it is inaccurate or processed in violation of the Privacy Shield Principles. To make such a request, please contact us at the contact details above.
We will consider and respond to your request in accordance with the Privacy Shield Principles and applicable laws.
We may retain your personal information as long as you continue to use the Services, have an account with us or for as long as is necessary to fulfil the purposes outlined in the policy. You can ask to close your account by contacting us at the details below and we will delete your personal information on request.
We may however retain personal information for an additional period as is permitted or required under applicable laws, for legal, tax or regulatory reasons, or for legitimate and lawful business purposes.