Effective Date: November 1, 2018
“Policy”) to describe the ways we collect, store, use, and manage the information, including
personal information, and data that our users (“users” or “you”) provide or we collect in connection
with the LongLoop or ShortPort website available at shortport.de and any LongLoop game provided
on a mobile platform (each a “Service,” collectively, the “Services”). Please note that the scope of
this Policy is limited to information and data collected or received by LongLoop through your use
of the Services. LongLoop is not responsible for the actions of individuals with no relationship to
LongLoop or third party companies, the content of their sites, the use of information or data you
provide to them, or any products or services they may offer. Any link to those sites does not
constitute our sponsorship of, or affiliation with, those individuals or companies.
Information and Data We Collect from You
When you use our Services, you may give us your contact information directly on our website,
generally your name and email address. We also collect certain information and data, such as your
application usage, access, session times and in-app purchases, your unique device ID, hardware
type, the version of your operating system (“OS”), your device name, your name, email address and
cover photos (if you have connected to Facebook or Google+), and your general (city/country)
location (based on your Internet Protocol (“IP”) address).
In addition, we create a unique user ID to track your use of our Service. This unique user ID is
stored in connection with your profile information to track the LongLoop games you are playing.
We may occasionally send you push notifications through our mobile applications to send you game
updates, high scores and other service related notifications that may be of importance to you. You
may at any time opt-out from receiving these types of communications by turning them off at the
device level through your settings.
We may collect non-personal information about you through our Service. Such information may
include your operating system type and version, and the time and date of your visit to the Service.
How We Use Your Information
LongLoop’s primary goals in using your information are to create your account, provide Services to
you, troubleshoot, improve and optimize our Services, contact you, conduct research and create
reports for internal use. We use information collected through our Service for purposes described in
this Policy or disclosed to you in connection with our Service. For example, we may use your
Create game accounts and allow users to play our games;
Identify and suggest connections with other LongLoop users;
Operate and improve our Services;
Understand you and your preferences to enhance your experience and enjoyment using our
Respond to your comments and questions and provide customer service;
Provide and deliver products and services you request;
Deliver advertising and marketing and promotional information to you;
Send you related information, including confirmations, invoices, technical notices, updates, security
alerts, and support and administrative messages;
Communicate with you about promotions, contests, rewards, upcoming events, and other news
about products and services offered by LongLoop and our selected partners;
Conduct and administer contests promoted by LongLoop;
Enable you to communicate with other users; and
Link or combine it with other information we get from third parties, to help understand your
preferences and provide you with better services.
Use of Your Information by Others
Third Party Services. Our Services may contain third party tracking and data collection and
analytics tools from our service providers, examples of which include AppsFlyer
( https://www.appsflyer.com ) and Helpshift ( https://www.helpshift.com ). Such third parties may use
cookies, APIs, and SDKs in our Services to enable them to collect and analyze user and device
related data and information on our behalf. The third parties may have access to and collect data and
information about you, such as your device identifier, geo-location information, IP address,
application usage, access and session times, applications present on the device or in use at a
particular time on the device, and your viewing of and interactions with advertising, for the purpose
of providing their services, including, for example, enabling, providing and delivering advertising
as described in further detail below.
The privacy policies of our service providers may include additional terms and disclosures
regarding their data collection and use practices and tracking technologies, and we encourage you to
check those privacy policies to learn more about their data collection and use practices, use of
cookies and other similar tracking technologies.
Advertising. To the extent we display advertising in our Services, we may allow advertising
networks of our affiliates and partner networks to collect information about your mobile device to
enable them to serve targeted ads to you. Such mobile device data includes the following:
Device make, model and operating system;
Device properties related to screen size & orientation, audio volume and battery;
Name and properties of mobile application through which a consumer interacts with the Services;
Country, time zone and locale settings (country and preferred language);
Network connection type and speed;
Internet browser user-agent used to access the Services; and
Identifier for advertisers (IDFA).
The privacy policies of our partners may include additional terms and disclosures regarding their
data collection and use practices and tracking technologies, and we encourage you to check those
similar tracking technologies.
You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU)
to learn more about interest-based advertising and how to opt-out of this form of advertising on
your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-
regulatory program. If you wish to opt-out of interest based advertising in mobile apps on your
device by companies that participate in the DAA’s AppChoices app, you may download that app
onto your device and exercise your choice. AppChoices is available at the links below:
• DAA AppChoices iOS
• DAA AppChoices Android
• DAA AppChoices Amazon
You may also limit data collection by third parties by using your mobile device settings. Please note
that electing to opt-out will not stop advertising from appearing in your browser or applications. It
may make the ads you see less relevant to your interests. Additionally, please not that if you use a
different browser or erase cookies from your browser, or use a different mobile device, you may
need to renew your opt-out choices.
How We May Disclose Your Information to Third Parties
LongLoop does not share your personal information except as approved by you or as described
We may share information we collect or derive with third parties for the following purposes:
With service providers that perform services on our behalf, including the ones referenced above
under “Third Party Services”;
With our affiliates;
For analytics and research purposes;
In response to subpoenas, court orders, or other legal processes;
To protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim;
As part of a business transfer such as a merger, acquisition, or at bankruptcy;
We may share aggregate or anonymous information about you with advertisers, publishers, business
partners, sponsors, and other third parties; and
We may use analytics services provided by third parties, including Google Analytics. These service
sites over time for non-advertising purposes. To learn more about how Google analytics collects and
processes data and the choices Google may offer to control these activities, you may visit
Specific Provisions for EU Individuals
Accessing and Correcting Your Personal Information. At any time, you may contact LongLoop
at the address provided in the “Contact LongLoop” section herein and request to access the personal
data that LongLoop holds about you. LongLoop may need to ask you to provide certain information
to make sure you are who you claim to be. If you find the information on your account is not
accurate, complete or updated, then please provide LongLoop with the necessary information to
Withdrawing Your Consent. Contact us if you would like to withdraw your consent to the
processing of your personal data. Exercising this right will not affect the lawfulness of processing
based on consent before withdrawal.
Erasing or Restricting Access to Your Information. You may request to delete or restrict access
to your personal data. We may postpone or deny your request if your personal data is in current use
for providing Services or for other legitimate purposes, in which case we will let you know if we
are unable to do so and why.
Transferring your Personal Data (Otherwise known as Your Right to Data Portability). You
have the right to receive your personal data that you have provided us in a structured, commonly
used and machine readable format and the right to transmit that data to another party of your choice,
where technically feasible. However, this right shall not apply where it would adversely affect the
rights and freedoms of others.
Right to Make Complaint: if you consider that our processing of your personal data infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible
for data protection. You may do so in the EU member state of your habitual residence, your place of
work or the place of the alleged infringement.
If you have any concerns about the way we process your personal data, you are welcome to contact
our data protection officer at firstname.lastname@example.org or write to us at the address set forth in the
“Contact LongLoop” section. We will look into your request and make good faith efforts to resolve
any concern you may have.
Security Safeguards. LongLoop takes reasonable measures to protect your information from
unauthorized access or against loss, misuse or alteration by third parties. Although we make good
faith efforts to store the information collected on the Services in a secure operating environment
that is not available to the public, we cannot guarantee the absolute security of that information
during its transmission or its storage on our systems. Further, while we attempt to ensure the
integrity and security of our network and systems, we cannot guarantee that our security measures
will prevent third-party “hackers” from illegally obtaining access to this information. We do not
warrant or represent that your information will be protected against, loss, misuse, or alteration by
third parties. No method of transmission over the Internet, or method of electronic storage, is 100%
secure, however. Therefore, we cannot guarantee its absolute security.
Data Retention. LongLoop retains your personal data for as long as needed to provide you
Services, unless we are required by law to delete or if LongLoop accepts your request to delete the
information. We will also retain and use your personal data as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.
Our Policy Regarding Children. We do not knowingly collect or solicit personal data from anyone
under the age of 16 or knowingly allow such persons to use our Services. If you are under 16,
please do not send any information about yourself to us, including your name, address, telephone
number, or email address. No one under the age of 16 may provide any personal data. In the event
that we learn that we have collected personal data from a child under age 16, we will delete that
information as quickly as possible. If you believe that we might have any information from or about
a child under the age of 16, please contact us.
Transfer of Personal Data Outside Your Country. We may transfer information that we collect
about you to affiliated entities, or to other third parties across borders and from your country or
jurisdiction to other countries or jurisdictions around the world. Please note that these countries and
jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps
to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use
and disclosure of information about you, including personal data, as described in this Policy.
Lawful Basis for Processing. On certain occasions, we process your personal data when it is
necessary for the performance of a contract to which you are a party, such as to provide the Services
to you. We may also process your personal data to respond to your inquiries concerning our
products and services.
On other occasions, we process your personal data where required by law. We may also process
your personal data if necessary to protect your interests or the interests of a third party.
Additionally, we process your personal data when necessary to do so for fraud prevention,
improving our network and services, and marketing our services to advertisers and publishers;
where these interests are not overridden by your data protection rights.
If the processing of personal data is necessary and there is no other lawful basis for such processing,
we will generally ensure that consent has been obtained from you. You have the right to withdraw
your consent to processing of personal data at any time.
For questions about data processing, please contact our Data Protection Officer. Visit the “Contact
LongLoop” section below for contact information.
Changes to This Policy. We may update this Policy to reflect changes to our data and information
privacy practices. If we make any material changes we will notify you by means of a notice on the
Services prior to the change becoming effective. We encourage you to periodically review this
Policy for the latest information on our privacy practices. Please note that if LongLoop needs to
adapt the policy to legal requirements, the new policy will become effective immediately or as
Privacy Shield Framework
LongLoop transfers certain personal data to the U.S. and participates in and has certified its
compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield
Framework. LongLoop is committed to subjecting all personal data received from European Union
(EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield
Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield
Framework visit the U.S. Department of Commerce’s Privacy Shield List, available
at: https://www.privacyshield.gov/list .
LongLoop is responsible for the processing of personal data it receives under the Privacy Shield
Framework and subsequently transfers to a third party acting as an agent on its behalf. LongLoop
complies with the Privacy Shield Principles for all onward transfers of personal data from the EU
and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework,
LongLoop is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
In certain situations, LongLoop may be required to disclose personal data in response to lawful
requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, LongLoop commits to resolve complaints about
our collection or use of your personal information. EU and Swiss individuals with inquiries or
complaints regarding our Privacy Shield policy should first contact us
at: email@example.com . We will attempt to answer your questions and satisfy your concerns
in a timely and complete manner. If you do not receive timely acknowledgment of your complaint
from us, or if we have not addressed your complaint to your satisfaction, please contact or visit
https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The
services of JAMS are provided at no cost to you.
If your complaint is still not resolved through these channels, under certain conditions, more fully
described on the Privacy Shield website here: https://www.privacyshield.gov/article?id=How-to-
Submit-a-Complaint , you may invoke binding arbitration when other dispute resolution procedures
have been exhausted.