Privacy Policy.
Version dated 16 February 2015

Market Making Limited (“us”, “we” or “our”) are committed to protecting the privacy of all users (“you” or “users”) of our games, applications, websites (“Sites”) and other services (together, “Services”). This privacy policy (“Privacy Policy”) sets out how we use and protect any personal information that you provide to us.

This Privacy Policy is intended to assist you in making informed decisions when using our Services. Please take the time to read and understand this Privacy Policy.

By using our Services and/or registering and subscribing for Services you consent to the collection, use and transfer of your information in accordance with this Privacy Policy.

1. CONTACTING US

For the purpose of the Data Protection Act 1998 (the “Act”), the data controller in respect of any personal data that you submit to us by any means including via any Site or by use of any Services is Market Making Limited, a company incorporated under English law (company number: 7913465) and whose registered office is at 10 Bethune Avenue, London, N113LE, England. We also use the trading name “Agency2”. We are registered with the Information Commissioner’s Office where our registration number is ZA067686

As set out below, if you access the Services via a third party Client of ours, both us and the Client may be co-controllers of the data, and the Client’s privacy policy will also apply.

If you want to know what information we hold about you or if you have any other queries in relation to this privacy policy, please contact us using the following information:

Market Making Limited, 10 Bethune Avenue, London, N11 3LE
Email: joel@socialinsightengine.com

Please use the phrase “Subject Access” in your email header or in the subject line of your letter if you are writing to enquire what information we hold about you. See paragraph 9 for more details.

2. WHAT INFORMATION DO WE COLLECT?

2.1 We will collect information that you provide to us when you sign up to or use our Services. We also collect information that you share with Facebook or any other social media provider through whom you access the Services (“Social Media Information”). Where we collect Social Media Information:

  • We only collect such information as is made public by you in your social media settings (we advise you always to check privacy settings when using social media and to keep them under review)
  • We only collect such information strictly in accordance with our own terms of business with the social media platform in question
  • We only use such information in accordance with this policy. Please see in particular paragraph 2.4 below.
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2.2 We may also collect information about you from e-mails or letters, or other communications that you send to us. We will only use such information in accordance with the terms of this Privacy Policy.

2.3 Whenever you play our personalised quotes app, we collect data to enhance the personalisation.

2.4 We may receive Social Media Information that you submit to any third party website that you access from a link contained in the Services, and in relation to any third party services you connect to our Services (e.g., Twitter, Facebook, Google + or Apple’s Game Center). Both Market Making Limited and the owner or operator of that third party website will be the data controller in respect of any such information and you should check the privacy policy of that website or third party service provider to find out how they will use your personal information. We are not responsible for any use of your personal data by any third party to whom you connect or access via the Services.

2.5 We will only use any information that we collect from you in accordance with this Privacy Policy.

3. COOKIES AND OTHER SIMILAR TRACKING TECHNOLOGY

3.1 Our Sites and Services may use cookies and other similar technologies to ensure that you get the most out of them. Cookies are small amounts of information in the form of text files which we store on your computer or device. Cookies allow us to monitor website traffic, improve our Site’s and Services’ usability and to personalise the content of the Site or Services for you. By using these technologies, we may collect information about your computer or device, your visits to our Sites, and usage of our Services. This information may include your IP address, MAC address, device type, operating system, geographical location, browser type, length of visit and number of page views or other Service session activity. In particular, we may use an analytics service provider for website traffic analysis and reporting and to track information such as which browser, screen resolution and IP address you are using to access our Services, in addition to tracking your movements around our applications or websites.

3.2 If you do not wish us to install cookies on your computer or device for these purposes, you may change the settings on your computer or device browser to reject cookies. For more information about how to do this please consult the “Help” section of your browser. Please note that if you do set your browser to reject cookies, you may not be able to use all of the features of the Site or access or use features of the Service.

3.3 We may use an analytics service provider for website traffic analysis and reporting, and to help us understand how our games, Sites, and Services are being used, such as the frequency and duration of usage. Analytics service providers generate statistical and other information about such usage by means of cookies and similar technologies, which are stored on users’ computers. The information generated may be used to create reports about such usage and the analytics service provider will store this information.

3.4 In addition, within our Sites and Services, we may feature advertisements served by third parties who may use and place cookies on your computer or device so the content you see and your interaction with the advertisement can be tracked each time you click on links for those adverts. This Policy does not apply to, and we are not responsible for such data collection. We encourage you to consult the terms and conditions and privacy policy of such third party advertisers to find out how they collect and use your personal data and to establish whether they use cookies and what they may use them for. For more information on how to manage third party cookies and similar technologies, please see Paragraph 6.2 below.

4. HOW DO WE USE THE INFORMATION THAT YOU PROVIDE TO US?

4.1 We use your personal information in the following ways:

a) to enable us to operate and provide our services;

(i) to ensure that content from our Services is presented in the most effective manner for you and your computer or device;

(ii) to provide customer service to you in relation to your use of our Services, to deal with enquiries and complaints relating to the use of Our Services and to notify you about any changes to the same;

(iii) to administer, support, improve, optimise and develop our Services;

(iv) to let you know about promotions, updates and other product news and services offered by us and our selected partners; and

(v) for security purposes

b) We process personal information for the purposes of providing Client Services for the benefit of and on behalf of our Clients. Client Services involve analysing the above information to create a picture of users’ lifestyle, interests and browsing and shopping intent as well as tastes and preferences. Our aim is to create groups of users with similar, interest or behaviour patterns, depending on our Clients’ specifications. We aim to use and hold data in an anonymised and aggregated form wherever possible and to only use identifying data which you have supplied to us.

c) The information may also be used for analytical and strategic development purposes, to measure the effectiveness of content and adverts and to provide users with a more personalised service on both our Site and our Clients’ websites.

5. DISCLOSURE OF YOUR INFORMATION

5.1 Other than as expressly set out in this Privacy Policy or as otherwise required or permitted by law, we will not share, sell or distribute any of the information you provide to us without your consent.

5.2 You should note that information posted on the public elements of our Services will be visible to users of the Services throughout the world. You should therefore be careful when submitting information about yourself to such areas (e.g., public forums).

5.3 We may disclose your personal information to (i) any third party to whom disclosure is necessary to enable us to provide you with any service to which you have subscribed via the Services; (ii) any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under the Terms and Conditions; (iii) any third party to whom disclosure is required by law, because a court or the police or other law enforcement agency has asked us for it, or where we believe that disclosure is appropriate to comply with the law.

5.4 We may disclose your information in the event of any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. Any such company will have the right to continue to use the personal and other information you provide to us in accordance with this Privacy Policy.

6. THIRD PARTY SITES AND SERVICES

6.1 Our Sites and Services contain links to, and allow you to connect to, websites and services that are operated by third parties (“TP Services”). We do not control and we accept no liability or responsibility for TP Services, and this Privacy Policy does not apply to the same. Please consult the terms and conditions and privacy policy of TP Services to find out how they collect and use your personal data and to establish whether they use cookies or other similar technology and what they may use them for.

6.2 Further information on how to opt-out of the use of cookies related to the delivery of advertising can be found here: http://www.networkadvertising.org. You can opt-out of Flurry Analytics here: http://www.flurry.com/user-opt-out.html.

7. HOW DO WE PROTECT YOUR INFORMATION?

7.1 The information that you provide to us will be collected and processed by us or by a data processor appointed by us to undertake processing on our behalf.

7.2 Appropriate security measures will be adopted to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. However, you acknowledge that data transmission over the internet is inherently unsecure and that we cannot guarantee the security of data you send over the internet.

7.3 Your information will only be held for a reasonable period or as long as the law requires or permits.

8. CHILDREN

We do not knowingly collect personal data from any child under the age of 13 without consent from their parent or guardian.

9. HOW CAN YOU ACCESS YOUR INFORMATION

You may at any time request access to and/or, if incorrect, rectification of your personal data by contacting us at the address set out in Paragraph 1 of this Privacy Policy or by e-mailing support@socialinsightengine.com. We reserve the right to ask you for proof of your identity and to charge you a fee of ten pounds sterling (£10) to meet our costs in granting any data access request you make.

10. CHANGES TO OUR PRIVACY POLICY

By using our Services, including browsing our Sites, you consent to our collection and use of your information as described in this Privacy Policy. If we change our privacy policies and procedures, we will post those changes on this page and update the date at the top of the page to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.

Any questions, please contact: support@socialinsightengine.com

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