Overview

This Privacy Policy describes the information collected by “Color Idea” app for Kids and Family ("we," "us" or "our") through our mobile applications and website and how we use that information.

About this Privacy Policy

This Privacy Policy (the "Privacy Policy") applies to the collection, use and disclosure of personal and non-personal information by E2 ICT Snc and its affiliates through the e2ict.it and app.e2ict.it websites (the "Sites"), the mobile apps published by E2 ICT Snc (the "Apps") (in this Privacy Policy, the Sites and Apps are referred to collectively as the "Platforms"). This Privacy Policy does not apply to the collection, use or disclosure of personal and non-personal information through any apps for which E2 ICT Snc is not the publisher.
Unity provides a hosted data collection, analysis, export and dashboard reporting platform for player, performance and other data.
By using the Platforms, you signify your assent to our Privacy Policy. If you do not agree to this Privacy Policy, please do not use any of our Platforms.
If you believe we have inadvertently collected such information, please contact us so we can promptly remove the information.
We reserve the right to make changes to this Privacy Policy at any time. Please check the Privacy Policy each time you use our Platforms to ensure you are aware of any changes in our privacy practices. Our Privacy Policy will indicate the date it was last updated. Your continued use of our Platforms will signify your acceptance of the changes to our Privacy Policy. If there is a substantive or material change in the way that we use your personal information, we will notify you via email of the relevant changes or provide other prominent notice. If you choose to opt-out of or not opt-in to our changed practice, our email communication (if applicable) will contain instructions on how to do so. If such change affects children users, we will first notify and obtain the prior verifiable consent of a parent or legal guardian.

How we protect the online provacy of children under 13

E2 ICT Snc takes many precautions to protect the online privacy of children. Whenever we refer to "children" in this Privacy Policy, we mean children under the age of 13. Please help us in protecting children's privacy by instructing them to never provide any personal information (full name, email address, home address, phone number, etc.) without your permission.

E2 ICT Snc follows the principles of the Children's Online Privacy Protection Act ("COPPA"), a U.S. law designed to protect the online privacy of children, in our online services and Apps that are directed to children. If you would like to learn more about COPPA, you can refer to the "Children's Privacy" section of the Federal Trade Commission's website.

Currently, E2 ICT Snc does not knowingly collect any personal information from children or within the child-directed portions of our Platforms except as otherwise outlined in this Privacy Policy. If we were to collect and store personal information from children, we would obtain the consent of a parent or legal guardian before such collection, unless the collection of information falls within an exception that is permitted under COPPA.
In our Apps directed to children users, we collect information which includes persistent identifiers such as a device identifier ("device ID") or an Internet Protocol address ("IP address"). This information is collected solely for the purpose of providing functionality and support for our internal operations and optimizing our users' game experience.
Our apps do not contain any third party advertising. We may from time to time promote other E2 ICT Snc apps within our apps. We try to ensure safeguards against children clicking these links by placing them a parental gate requiring a calculation.
E2 ICT Snc does not permit behaviorally-targeted advertising to children in the Apps or in the Platforms where we have actual knowledge that the user is under the age of 13.
If you believe that we may have unintentionally collected your child's personal information without your prior consent, you may contact E2 ICT Snc' Privacy Officer:
By email: support[at]e2ict.it
By phone: +39 0832 318125
By post mail:  E2 ICT Snc - Via Bartolomeo ravenna, 15 - 73100 Lecce (LE) ITALY

Information collected by E2 ICT Snc

There are two types of information that may be collected by E2 ICT Snc.

The first is called personal information which is information that can be used to identify a specific individual. As stated in the previous section, E2 ICT Snc does not knowingly collect any personal information from children outside of the information required for the support of internal operations. E2 ICT Snc may collect personal information that parents, legal guardians or persons over 13 voluntarily provide on the Platforms.

The second type of information is non-personal information which doesn't directly identify an individual. E2 ICT Snc may collect non-personal information about your use of the Platforms to help us improve our services or for other purposes as described in this Privacy Policy.
We may combine the non-personal and personal information you provide us through our Platforms. Information collected will vary depending upon the activity and may include your name, email address, phone number, mobile number, device type, operating system, home address, birth date, statistical and usage data (as further explained below), proof of identify (such as the Social Security, Social Identification Number or Social Insurance Number) of contest prize winners and, to the extent required to process any payment, your credit card information. In addition, we may collect demographic information such as gender, zip code or postal code and other data that you may provide in surveys or online profiles, for instance. We may combine demographic information with personal information.

Our Websites/App/Platforms may contain APIs from third parties.

Our third party partners, and their privacy policies are as follows:

Google Analytics:
http://www.google.com/analytics/learn/privacy.html
Google Advertisement (Google Adsense, Admob):
http://www.google.com/intl/en/policies/technologies/ads/
https://www.google.com/settings/u/0/ads

Purposes for which we use the information collected

E2 ICT Snc may use the personal information you provide us for the purposes of newsletter sign-up or improving our products and services. You are not required to provide personal information to us to obtain access to any of our Platforms.

• Statistical and Usage Data: When you use our Apps on your device, we may retrieve information about your hardware system and how your game is played, including your IP address or device ID. We may also collect information about your computer, hardware, software, platform, media, connection, information about online activity such as feature usage, game play statistics and scores, user rankings, click paths, and in-app purchases. We use this information to better understand the behavior and preferences of our customers, so that we can improve our products and services. We work with a third party analytics company (Google Analytics - http://analytics.google.com/) to help us collect and analyze this information with the goal of improving our Platforms and providing you with the best services.
• Other Uses: We may also use your information for other legitimate business purposes. Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill the purposes for which it was collected and our legitimate business objectives or as permitted or required by law.
• Use of "Cookies": Our Sites may use cookies to enhance your experience while using them. Cookies are pieces of information that some websites transfer to the computer that is browsing that website and are used for record-keeping purposes at many websites. Use of cookies makes Web-surfing easier by performing certain functions such as saving language preferences and maintaining your sessions while you are on our Sites. The cookies used on our Sites contain generic information used for page navigation. If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, some areas of our Sites may not function properly. We also use cookies related to the use of Google Analytics on our Sites. Google Analytics uses first-party cookies to report on visitor interactions. These cookies are used to collect information about how visitors use our Sites. We use the information to compile reports and to help us improve the Sites. You can opt out of tracking by Google Analytics by visiting: https://tools.google.com/dlpage/gaoptout?hl=it-IT.In any event, we do not link information collected through cookies with any personally identifiable information.
• Internet Protocol Address: We collect an IP address from every visitor to our Platforms. An IP address is a number that is automatically assigned to your computer or device when you use the Internet. We use IP addresses to help diagnose problems with our servers, administer our Platforms, analyze trends, track users' movement on our Platforms, gather broad demographic information for aggregate use in order for us to improve the Platforms, and deliver customized, personalized content. We do not link IP addresses with any personally identifiable information.

How we share or disclose information

• Partners: E2 ICT Snc may share non-personal information with our brand partners, which may include without limitation game session information, retention, purchases, gameplay events and user behavior. E2 ICT Snc does not share any personal information with these partners.
  We may from time to time promote other E2 ICT Snc apps within our apps. We try to ensure safeguards against children clicking these links by placing them in a parents section or requiring a calculation.
• Marketing: The personal information you provide will allow us to alert you to new products, features and enhancements; special offers; upgrade opportunities; and contests and events of interest; send you push notifications (if you choose to allow that function); this data may be used for internal purposes such as personalization of content and contextual (not behavioral) advertising. From time to time, we may also inform you on other companies and organizations that provide products or services that we believe may be of interest to you. We see this as a value-added service helping you to find useful products or services. We strive to limit use of the information you provide to those offers that we think you would appreciate receiving. You may opt out of this service by contacting us as set out in the opt-out provision below. Currently, E2 ICT Snc does not share personal information with third parties for marketing purposes (except to the extent required by law, court order, or as requested by other government or law enforcement authority).
• Service Providers: We may transfer personal information to third party service providers that perform services on our behalf (e.g. processing payment) or otherwise collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy. Some of these service providers may be located in a country other than where you reside, including in the United States, and your personal information may be stored or processed in those countries. We take reasonable contractual measures to ensure that our service providers provide appropriate protection for your personal information and use your personal information only for the purpose of providing the services to us. Your personal information is subject to the legal requirements of the country in which it is located, including lawful requirements to disclose information to government authorities in those countries. Our employees and those of our agents and service providers who require it in order to fulfill their job requirements will have access to your personal information.
• Legal Rights and Obligations: Finally, we may use and/or disclose your personal information to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage. When necessary, we may also disclose personal information to law enforcement, or to the appropriate civil authorities. E2 ICT Snc does not knowingly share or disclose personal information other than as set forth in this Privacy Policy.

Other important information

Opt-Out Provision: Currently, E2 ICT Snc does not share personal information with third parties for marketing purposes. In the event this was to happen, E2 ICT Snc would obtain your consent prior to any such disclosure. If you do not want E2 ICT Snc to send you postal mail about our products and services, you can opt out at any time and choose to have your name removed from our mailing list.

You can do so by contacting E2 ICT Snc' Privacy Officer:
By email: support[at]e2ict.it
By phone: +39 0832 318125
By post mail:  E2 ICT Snc - Via Bartolomeo ravenna, 15 - 73100 Lecce (LE) ITALY

By providing us your email, you accept to receive emails from E2 ICT Snc with respect to our products and services. Additionally, by providing E2 ICT Snc with your email on Facebook, such as through a sweepstakes or a newsletter sign-up, you accept to receive emails from E2 ICT Snc with respect to our products and services. If you opt to receive such communications, you may opt out of this consent at any time by contacting us as described above or by using the unsubscribe mechanism included in the email communications you will receive. You may also modify your user settings to edit the email address related to your account or opt-out of receiving emails, at any time.
You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice, by contacting us as described above. Please note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services.

Safeguarding Your Personal Information: We will only collect and use personal information in accordance with this Privacy Policy to the extent deemed reasonably necessary to serve our legitimate business purposes, and we will maintain appropriate safeguards to ensure the security, integrity, accuracy and privacy of the information you have provided. In addition, we will take reasonable steps to assure that third parties to whom we transfer any personal information will provide sufficient protection of that information.

Third Party Sites: If you click on a link to a third party site, including on an advertisement, an Ad Provider link, or other third party service, you will leave the E2 ICT Snc Platform you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as E2 ICT Snc. We encourage you to review the privacy policies of these third party sites from whom you request services. If you visit a third party website that is linked to on a E2 ICT Snc' Platform, you should consult that site's privacy policy before providing any personal information on that site.

Reviewing, Correcting and Deleting Your Information, Requesting Removal from Mailing Lists and Deactivating Your Account: If you wish to request access to your personal information or request that such information be corrected or deleted, or if you have any questions, comments, or concerns about this Privacy Policy or the information practices of E2 ICT Snc, please contact E2 ICT Snc' Privacy Officer (contact information below). Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.
If we have unintentionally collected and stored any personal information from children under 13, parents can request access to review such information, have it deleted, or stop our further collection or use of such information. To make any of these requests (when applicable), please use the contact information below.

Consent: Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified at the time that we collect the information from you or as otherwise described in this Privacy Policy. In the case of children under 13, as applicable, we will obtain a parent or legal guardian's verifiable consent prior to the collection of personal information from such users, unless the collection of such information falls within an exception that is permitted under COPPA.
Contact Information:
By email: support[at]e2ict.it
By phone: +39 0832 318125
By post mail:  E2 ICT Snc - Via Bartolomeo ravenna, 15 - 73100 Lecce (LE) ITALY

Policy Updates

This Policy may change from time to time. The most current version of our Privacy Policy can be found at http://app.e2ict.it/privacy/coloridea/index.html. We will always keep this up to date so that you know what information we will collect from you, how we may use it, and when we may disclose it.

Complaints

You can lodge a complaint with us about any breach of our Privacy Policy at the address below.

Privacy Policy Contact Information

If you have any questions about our Privacy Policy, please contact us at: support@e2ict.com

Last updated February 10, 2017