Last Updated: Sep 15, 2020
Recoded Ltd (“Recoded”, “us”, “our” or “we”) develops and
describes the ways we collect, store, use, and disclose the information,
including personal information, and data that our users (“users” or “you”)
provide or we collect in connection with the Recoded website available
and any Recoded product provided on a
mobile platform (each a “Service,” collectively, the “Services”). Additionally,
this Policy describes your rights and choices concerning your information.
Please note that the scope of this Policy is limited to information and
data collected or received by Recoded through your use of the Services.
Recoded is not responsible for the actions of individuals with no
relationship to Recoded 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.
If you do not want Recoded to collect, store, use, or share your information
in the ways described in this Policy, you should not use our Services.
2. Information and Data We Collect from You and How We Collect It
When you use our Services, you may give us your contact information directly
on our website, generally your name and email address.
We may also offer you the option to complete a user profile that is visible
to other Recoded users (“Account”). If you create an Account, you may provide
us you name, a username, e-mail address, a password and other information that
helps us confirm that it is you accessing your Account. We may do this through
in-product dialog boxes, which you may choose to skip. If you sign into the Services
with Facebook Connect we will collect information that is visible via your Facebook
account such as: (1) your first and last name, (2) Facebook ID, (3) Profile
Picture/URL,and (4) list of Facebook friends. Your Account may be used to publicly
identify you as part of social features of the Services, which may include user-to-user
interaction, chat or messaging functionality, public leaderboards, head-to-head
competition, and other similar features. The Recoded username will be public and
will be shown to other users, but will only permit access to information that is
considered public or that you have designated as public in your user profile settings.
We may also offer you the ability to import your contacts or manually enter
e-mail addresses so that you can locate your contacts on Recoded and invite
your contacts to join you in the Services. We will store those contacts for
purposes of helping you and your contacts make connections through our Services.
When you order any good or service through the Services, including any virtual
currency or virtual good, our payment processing service provider will collect
your name, phone number, e-mail address, mailing address, billing address, and
complete credit card information that enables them to receive your payment. Our
payment processing service provider may also retain this information to enable
you to purchase additional items through our Services without having to re-enter
it each time. Please note that purchases from third parties may also be subject
to additional policies
Information Collected by Customer Support
When you ask for assistance from our Customer Support team, we will collect
and store the contact information you provide (generally your name and e-mail
address), information about your activity on the Services, and
your user name or ID number. We will also store the correspondence and any
information contained within.
Technical and Usage Information
When you access our Services, we may collect (i) certain technical information
about your mobile device or computer system, including IP Address, mobile device
ID (IDFA, Google Advertising ID or other identifiers), and the version of your
operating system; and (ii) usage statistics about your interactions with the
Services. In certain Services we will create and assign to your device an identifier
that is similar to an account number. We may collect the name you have associated
with your device, device type, telephone number, country, and any other information
you choose to provide, such as username, character name, or e-mail address. We may
also access your contactsto enable you to invite friends to join you in the Services.
This information is typically collected through the use of third-party mobile device
software development kits. We may occasionally send you push notifications through
our Services to send you product 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.
3. How We Use Your Information
Recoded'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 information to:
- Create accounts and allow users to use our Services;
- Identify and suggest connections with other Recoded users;
- Operate and improve our Services;
- Understand you and your preferences to enhance your experience andenjoyment
using our Services;
- 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 Recoded and our selected
- Conduct and administer contests promoted by Recoded;
- Enable you to communicate with other users;
- 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. We may provide your information to third party companies
to perform certain services, including but not limited to hosting services,
payment processing, analytics, customer service and to assist us in our marketing
efforts. Where we share your information with third-party service providers and
business partners, we ensure that we have appropriate agreements in place to protect
your information as required by applicable data protection laws.
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;
- Operating system;
- 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;
- IP Address;
- Internet browser user-agent used to access the Services;
- Advertising ID (IDFA on iOS devices and GAID on Android devices).
The privacy policies of our partners may include additional terms and
disclosures regarding their data collection and use practices. We encourage you to
check those privacy policies to learn more about their data collection and use practices.
You may visit
(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.
4. How We May Disclose Your Information to Third Parties
Recoded does not share your personal information except as approved by you or as described herein.
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;
- When we have a good faith belief that we have to disclose the information in response to
lawful requests by public authorities, including law enforcement or legal process purposes;
- To satisfy any applicable laws or regulations;
- When we believe in our sole discretion that our Services are being used in committing a crime,
including to report such criminal activity or to share information with other companies and
organizations for the purposes of fraud protection, credit risk reduction, and other security
- 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;
- 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
5. Specific Provisions for EU Individuals
Accessing and Correcting Your Personal Information. At any time, you may contact Recoded at the
provided in the “Contact Recoded” section herein and request to access the personal data that
Recoded holds about you. Recoded 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
then please provide Recoded with the necessary information to correct it.
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
or write to us at the address
set forth in the “Contact Recoded” section. We will look into your request and make
good faith efforts to resolve any concern you may have.
6. Security Safeguards
Recoded 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
7. Data Retention
Recoded retains your personal data for as long as needed to provide you Services,
unless we are required by law to delete or if Recoded 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.
8. 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.
9. 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.
10. 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 Recoded” section below for contact information.
11. Privacy Shield Framework
Recoded 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. Recoded 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
Recoded 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. Recoded complies with the Privacy Shield Principles for all onward transfers
of personal data from the EU and Switzerland, including the onward transfer liability
With respect to personal data received or transferred pursuant to the Privacy Shield
Framework, Recoded is subject to the regulatory enforcement powers of the U.S. Federal
Trade Commission. In certain situations, Recoded 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, Recoded 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:
. 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
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:
, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
12. Specific Provisions for California Consumers
These additional provisions for California consumers apply only to individuals who reside in California.
The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt
and requires “businesses” collecting or disclosing personal information to provide notice and a means
to exercise those rights.
Categories of personal information collected in the preceding 12 months:
- Information We Collect From You
Business purpose for collection
- How We Use Your Information
Third parties with whom we may share your information
- Use of Information by Others
Right to Know and Right to Delete
For any of the personal information described above, you can request to know
what personal information we collected, disclosed, used and sold, and request
that we delete your personal information at any time.
To exercise your right to know and right to deletion, please submit a request by:
with the subject line “California Rights Request.” We will need to verify
your identity before processing your request. In order to verify your identity,
we will generally require the matching of sufficient information you provide us
to the information we maintain about you in our systems. In certain circumstances,
we may decline a request to exercise the right to know and right to deletion,
particularly where we are unable to verify your identity.
Upon verification of your request, we will delete (and direct our service
providers to delete) your personal information from our records, unless
retaining the information is necessary for us or our service providers to
complete the transaction with you, detect security incidents or fraud, fixing
errors, exercise free speech or another right provided by law, comply with
legal obligations, or other internal and lawful uses.
Right to Opt Out of Sale
CCPA gives you a right to direct a business that sells your personal information
to stop selling your personal information and to refrain from doing so in
the future. We do not sell any of your personal information and will require our
service providers not to sell your personal information.
You also have the right not to be discriminated against for exercising any of the rights listed above.
If you are a California resident seeking to exercise your rights under the CCPA or have any
questions or concerns, please email us at
In certain circumstances, you are permitted to use an authorized agent to submit requests
on your behalf where (i) you provide sufficient evidence to show that the requestor is an
authorized agent with written permission to act on your behalf and (ii) you successfully
verify your own identity with us.
We aim to respond to a consumer request for access or deletion within 45 days
of receiving that request. If we require more time, we will inform you of
the reason and extension period in writing.
13. 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 Recoded
needs to adapt the policy to legal requirements, the new policy will become effective
immediately or as required.
14. Contact Recoded
You may contact Recoded’s Data Protection Officer at