The defined terms in this Policy have the same meaning as in Our Terms and Conditions, which You should read together with this Policy. By accessing Our Site and/or the Skrilla Application and using the Services, You consent to the terms of this Policy and agree to be bound by it and Our Terms and Conditions, even when they are unilaterally amended. A current version of this Policy will always be made available on Our Site.
3. Special note about children
We do not offer the Services to, or knowingly collect or solicit information from, anyone under the age of eighteen (18). Accordingly, We do not knowingly collect age identifying information, nor do We knowingly collect any Personal Information (defined below) from children under the age of thirteen (13). If You are under thirteen (13), do not create a User account, use or provide any information through the Services or on or through any of its features, make any purchases, use any of the interactive or public comment features, or provide any information about Yourself to Us. In the event We discover that anyone under thirteen (13) has provided Personal Information to Us, in accordance with Our policies and the Children’s Online Privacy Protection Act, We will delete that person’s Personal Information from Our files to the extent technologically possible. If You believe We might have any information from or about a person under thirteen (13), please send an email to firstname.lastname@example.org, with the subject heading “Children’s Online Privacy Protection Act.”
4. Information Skrilla collects
In order to operate the Services and provide You with access to certain features, Skrilla may collect the following types of information from You:
(i) Personal information by which You may be identified (“Personal Information”) as well as information that may not be personally identifiable standing alone (for example, Your age), but which may become personally identifiable when combined with Personal Information (for example, Your age combined with Your name); and
(ii) Information about You and Your activities on the Services that does not identify You personally (“General Information”), such as Your domain server, mobile device type, web browser, the operating system or platform You use, referrer data identifying the web pages You visited prior to and after accessing the Services, and Your movement and activity within the Services.
A. Personal information
Skrilla may collect Personal Information directly from You when You interact with Us directly through the Services, such as when You create a User account, use the Services, post to the Skrilla Customer Support Portal or on Our blog, contact the Skrilla Support Team, post to Social Media (Facebook, Twitter, Instagram and Reddit), and visit Our Site. The Personal Information Skrilla may collect and maintain about You includes:
- Contact information, such as legal first and last name, residential address, and mobile number;
- Date of birth;
- Social security number (for U.S. residents), Social insurance number (for Canadian residents), Drivers license number (for Australian residents);
- Display name and password;
- Unique identifiers, such as an Internet Protocol (IP) address, a processor or device serial number or other unique device identifiers, that are combined with Personal Information; and
- Location coordinates (longitude, latitude, and radius) if You use Your mobile phone or a GPS equipped device to access the Services;
- Banking information and/or credit card information; and
- Digital wallet address
You can always choose not to provide Your Personal Information to Skrilla, but it may mean that We are unable to provide You with the Services.
B. General information
In addition to collecting Personal Information from You, We may use a variety of technologies that automatically collect General Information. General Information is information about You or Your use of the Services that does not identify You personally. This includes Your domain server, device type, web browser, the operating system or platform You use to access the Site or download the Skrilla Application as well as referrer data identifying the web pages You visited prior to and after visiting the Site and Your movement and activity within the Services.
Technologies used within the Services to collect General Information may include, but are not limited to:
- Cookies. We may place files called “cookies” onto Your device. Cookies are data text files that sites store on a device for record keeping purposes when You visit them. The cookie file then identifies You as a unique user. Cookies make Your use of the Services more efficient by “personalizing” Your experience on the Services and gathering statistical data, such as which parts of the Services You have previously visited, what material You downloaded, Your Internet provider’s domain name and country, and the addresses of the web pages You visited immediately before and after accessing the Services. Cookies enable Skrilla to tailor the information You receive and to assist Skrilla and third parties providing services on Our behalf by identifying You as a User of the Services. While some cookies are deleted when You close Your browser, others remain even after Your browser is closed. Most web browsers automatically accept cookies, unless You have configured Your browser not to accept them. You can program Your browser not to accept cookies, but if You do, You may not be able to use certain portions of the Services and the Services will not be able to customize certain features according to Your preferences.
The Services may also use Flash cookies, also known as local shared objects or persistent identification elements, to collect and store information, including information about Your use of and preferences on the Services. Flash cookies are managed by separate browser settings and can be controlled by visiting the Adobe® Flash® Player site at: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
- Log Files. We may automatically record certain information that Your web browser sends when You visit a site. This information is recorded in server logs and contains such things as the requests You make through Your web browser, Your Internet Protocol (IP) address, browser type, browser language, referring and exit sites and URLs, platform type, clickstream data, domain names, landing pages, web pages viewed, the amount of time spent on particular web page, the time and date of any request You make through Your web browser, and any cookies used to uniquely identify Your web browser.
- Mobile Device Identifiers. Certain mobile service providers uniquely identify mobile devices and Skrilla and/or third parties providing services on Our behalf may receive such device information if You access the Services through a mobile device. Certain features on the Services may require collection of mobile phone numbers and Skrilla may associate that phone number to mobile device identification information. Additionally, some mobile service providers operate systems that pinpoint the physical location of devices that use their services. Depending on the provider, Skrilla and/or third parties providing services on Our behalf may receive this information.
- Analytics Data. We may use tools called “Segment,” “Facebook Pixel,” “HotJar” and “Google Analytics” to collect general information about Your use of the Services. These tools collect information such as usage data, which We use only to improve the Services.
- Support Data. We may use a tool called “Zendesk” to collect general information about Your use of the Services to collect information. This tool collects information such as the operating system and browser You use and information about the pages You visited prior to Your support request.
We may combine the General Information collected through the use of these tools with Personal Information.
5. How we use information collected
The information collected by Skrilla will be used for a variety of business purposes, including, for example, to operate, maintain and provide You with the features and functionality of the Services. This includes (but is not limited to):
- Processing Your registration, including verifying Your identity;
- Providing You with access to the Services;
- Confirming Your eligibility to use the Services;
- Completing a transaction that You have requested related to the Services;
- Processing payments and refunds related to the Services;
- Responding to Your inquiries, providing customer services, and resolving any complaints;
- Promoting, marketing and communicating with You regarding certain products or offerings available through the Services;
- Working with affiliates to provide You with offers;
- Improving the quality and design of the Services, and to create new features and functionality, promotions and services;
- Anonymizing or aggregating Your information for business purposes, including for reporting and research purposes;
- Alerting You to changes to the Services and/or the Skrilla Terms and Conditions;
- Enforcing compliance with the Skrilla Terms and Conditions;
- Complying with any applicable laws and regulations; and
- For any other purposes disclosed to You at the time Your information is collected or pursuant to Your consent.
By using the Services, You consent to Your Personal Information being collected, held and used in this way and for any other use You authorize. Skrilla will only use Your Personal Information for the purposes described in this Policy or only with Your express permission in any other event.
It is Your responsibility to keep Your password to the Services safe. You should notify Us as soon as possible if You become aware of any misuse of Your password, and immediately change Your password within the Services or via the Forgot your Password process, which can be accessed from the Log In page of the Services.
6. How we share your information
Skrilla may share Your Personal Information as set forth in the following circumstances:
- Third Party Service Providers. In some cases, We may employ third party service providers such as third party payment processors to perform certain services on Our behalf, including, without limitation: (i) processing and fulfilling Your transactions; (ii) providing customer service; (iii) processing payments; (iv) hosting Our databases; (v) performing business analysis, data processing and/or quality control; (vi) providing marketing assistance, search results and links (including, without limitation, paid listings and links); and (vii) performing User and location verification services. Consequently, We may share Your Personal Information with these third party service providers if they need it to perform services on Our behalf. However, use of the Personal Information shared is strictly limited to the performance of the task We request and for no other purpose. All third parties with whom We share Personal Information are required to protect it in a manner similar to the way We protect information.
- Contests, Tournaments, and Promotions. From time to time, Skrilla may offer contests, tournaments, and other promotions that may require registration. If You choose to enter a contest, tournament, or promotion, Your Personal Information may be disclosed to third parties in connection with the administration of such offering, such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. By entering a contest, tournament, or promotion, You are agreeing to the official rules that govern that offering, which may contain specific requirements of You, including, except where prohibited by law, allowing Us and/or other parties to use Your name, voice and/or likeness in advertising or marketing materials.
- Disclosure of Personal Information for Legal and Administrative Reasons. If We believe in good faith that it is necessary and appropriate, We may disclose Your Personal Information without notice: (i) to cooperate in investigations of fraud, intellectual property infringement or any other activity that is illegal or may expose Us or You to legal liability; (ii) when required by law or to comply with a court order, subpoena, search warrant or other legal process; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view Your Personal Information); (iv) to protect and defend the rights, property or safety of Us, Our affiliates, subsidiaries and partners and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the other Users of the Services; (v) to verify the identity of the Users; (vi) to protect the security and integrity of the Services; (vii) to protect the rights, property or personal safety of Skrilla, Our Users or others; and (viii) to enforce the Skrilla Terms and Conditions. Where possible and appropriate, We will notify You if We are required by law to disclose Your Personal Information.
- Business Transfers. Your Personal Information may be transferred, sold or otherwise conveyed (“Conveyed”) to a third party where We: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of Our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganized. You consent to any and all such Conveyances of Your Personal Information.
7. Skrilla holds your personal information on servers located in Australia
All data, including Personal and General Information, that is entered into the Services by You, or automatically imported on Your instruction, is transferred to Skrilla’s servers as a function of transmission across the Internet. By using the Services, You consent to Your Personal Information being transferred to Our servers as set out in this Policy. Currently Our servers are located in Australia, and Your Personal Information will be routed through, and stored on, those servers as part of the Services. If the location of Our servers change in the future, We will update this Policy. You should review Our Policy regularly to keep informed of any updates.
By providing Your Personal Information to Skrilla, You consent to Skrilla storing Your Personal Information on servers hosted in the Australia. While Your Personal Information will be stored on servers located in Australia, it will remain within Skrilla’s effective control at all times. The server host’s role is limited to providing a hosting and storage service to Skrilla, and We have taken steps to ensure that Our server hosts do not have access to, and use the necessary level of protection for, Your Personal Information.
If You do not want Your Personal Information to be transferred to a server located in the Australia, You should not provide Skrilla with Your Personal Information or use the Services.
8. Storage of payment details
If You choose to transact on the Services, Your credit card details are not stored by the Services and cannot be accessed by Skrilla staff. Your credit card details are encrypted and securely stored by a third party payment gateway. However, Your bank account details and digital wallet addresses (if You decide to save such information with the Services) will be stored.
9. Accessing and updating your personal information
You are responsible for helping Us to maintain the accuracy and completeness of Your Personal Information. We urge You to review Your Personal Information regularly to ensure that it is correct and complete. If You would like to review Your Personal Information or if You believe that any of Your information is incorrect or has changed, please send an email to email@example.com, with the subject heading “Update Personal Information” and state the Personal Information You would like to review or provide the relevant Personal Information to be updated.
Skrilla will process Your request as soon as reasonably practicable, provided We are not otherwise prevented from doing so on legal grounds, or Your identity cannot be verified. If We are unable to meet Your request, We will let You know why. For example, it may be necessary for Us to deny Your request if it would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not reasonable and practicable for Us to process Your request in the manner You have requested.
10. How long user information is kept/protection of your information
We will only keep Your Personal Information for as long as We require it for the purposes of providing You with the Services. We may keep a copy of Your Personal Information in Our archives for as long as We reasonably need it. We may alter this practice according to changing requirements. For example, We may delete some data if needed to free up storage space. We may keep other data for longer periods if applicable law requires.
We are committed to protecting the security of Your Personal Information and We take all reasonable precautions to protect it from unauthorized access, modification or disclosure. Your Personal Information is stored on secure servers that have SSL Certificates issued by leading certificate authority Comodo, and all data transferred between You and the Services is encrypted.
We conduct Our business with great respect for the confidential nature of the information being provided and have security standards and procedures in place designed to prevent unauthorized access to Your Personal Information, to ensure that Your Personal Information is kept confidential, and that it is used only for the purposes for which it was collected. Consistent with industry standards and practices, We maintain physical, electronic, and procedural safeguards, which We review, refine, and upgrade as We deem appropriate based on new tools becoming available, to protect Your Personal Information. The safety and security of Your Personal Information also depends on You. Where We have given You (or where You have chosen) a password for access to certain features of the Services, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although We do Our best to protect Your Personal Information, We do not guarantee, and You should not expect, the security of Your Personal Information or private communications transmitted to Us via the Internet. Email is generally not a secure means of transferring information. We therefore cannot guarantee that this information will not be lost or used in a fraudulent manner and We encourage the use of email encryption to communicate with Us. Any transmission of Personal Information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
We will advise You at the first reasonable opportunity upon discovering or being advised of a security breach where Your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorized persons or in any unauthorized manner.
11. You can opt-out of any email and push notification communications
Your Personal Information will not be sold to advertisers or spammers. Skrilla sends product information, Services updates and Services notifications to You via email and push notifications. Our emails will contain clear and obvious instructions on how to unsubscribe. If You do not wish to receive push notifications You can turn these off in Settings/Notifications within the Site or the Skrilla Application. Skrilla will also remove You at Your request if You send an email to firstname.lastname@example.org, with the subject heading “Opt-out.”
Please note that even if You opt-out or unsubscribe from promotional offers or other marketing messages, We still may need to share Your Personal Information or send communications relating to Your use of the Services, such as a transaction initiated by You, including, without limitation, signing up for subscription services, or for other legitimate non-marketing reasons.
12. Public forums
13. Other websites/links
The Services may contain links to external third party sites that We do not own or operate. This may include links from advertisers, sponsors and/or partners that may use Our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these third party sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies to Your device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of Our offerings (including those linked to through an email or social networking page).
14. California privacy rights
California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request You should send (i) an email to email@example.com, with the subject heading “California Privacy Rights,” or (ii) a letter to P.O. Box 458, Fortitude, Queensland, Australia, 4005. In Your request, please attest to the fact that You are a California resident and provide a current California address for Our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in Our response. We reserve the right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
15. Do not track
We may work with third parties that use tracking technologies on the Site, including in order to provide tailored advertisements on Our behalf and on behalf of other advertisers across the Internet. These companies may collect information about Your activity on the Site and other sites over time, as well as Your interaction with Our advertising and other communications, and use this information to determine which ads You see on third party sites and applications. For more information about this practice and to understand Your options, please visit http://www.networkadvertising.org/ or http://www.aboutads.info.
17. How to contact us
Skrilla will endeavor to:
- Provide an initial response to Your query or complaint within 2 business days; and
- Investigate and attempt to resolve Your query or complaint within 10 business days or such longer period as is necessary and notified to You by Our respondent.
For further information please see Our Customer Queries, Disputes and Complaints Policy at https://help.skrilla.com/hc/en-us/articles/115010094568-Customer-Queries-Disputes-and-Complaints-Policy.
18. OFFICE OF THE AUSTRALIAN INFORMATION COMMISSIONER
If You are an Australian resident and have a complaint about how We handle Your Personal Information, You can also contact the Office of the Australian Information Commissioner by sending a letter to the Office of the Australian Information Commissioner at GPO Box 5218, Sydney NSW 2001, or You may call 1300 363 992. Additional information may be found at oaic.gov.au.