Privacy Notice

Your privacy is important to us. As a data controller domiciled in Finland Grey Area Oy shall collect and process your personal data in accordance with applicable Finnish laws, rules and regulations. This document is a data file description meant in Section 10 of the Personal Data Act (523/1999). In addition this document sets out the principles pursuant to which we process your location data.

1 CONTROLLER

Grey Area Oy (the "Controller")
Kaisaniemenkatu 6 A, 8th floor, 00100 Helsinki, Finland
email: [email protected]

2 NAME OF THE DATA FILE

Shadow Cities™ (the “Service”) End User Database

3 PURPOSES OF THE PROCESSING

Personal and location data is processed in order provide you with the Service, to maintain and administer the client relationship and for business and product development purposes. For sake of clarity, your location may be shared with other users of the Service. The data can also be used to provide you with interesting offers and promotions regarding the Service, other products and services of the Controller and, subject to your prior opt in, such third parties whose products and services the Controller thinks might be of interest to you. Location data is used solely for the provision of the Service.

4 CONTENTS OF THE DATA FILE AND SOURCES OF PERSONAL DATA

The data file contains data collected or submitted on the Service. In the Service and by registering we may receive the following information or parts of it:

Email
Facebook ID
Chat logs
Your known location (latitude and longitude coordinates), subject to your opt-in
In-game purchase history

The data is collected directly from uses of the Service by requesting such data and by automatic technical means.

5 DISCLOSURES OF DATA

We may disclose your personal data to such suppliers and subcontractors we engage to provide the Service or process the data on our behalf. We may also disclose your personal data to a third party who acquires Controller’s Service-related business or any other party taking over the operation of the Service.

Said suppliers and subcontractors may also be located in the United States. Controller shall disclose personal data of European Union residents only to such third parties in the United Sates who participate in the “safe harbour” framework set forth by the U.S. Department of Commerce. Safe harbour framework pursues to ensure that the participating party has undertaken to adequately protect any personal data disclosed to it. Learn more about the U.S. Department of Commerce Safe Harbor Program at http://www.export.gov/safeharbor/eu/.

Our partners and suppliers may gather personal data for their own purposes and collection of such data is subject to Privacy Policies of the respective parties. Such parties include Apple, Inc., iTunes SARL or any other such company that may from time to time make available Apple’s App Store.

6 DATA SECURITY

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

7 YOUR ACCESS TO DATA

You can access all your personal information that we collect. We use this procedure to better safeguard your information. You can correct factual errors in your personal information by sending us a request that credibly shows error.

To protect your privacy and security, we may also take reasonable steps to verify your identity before granting access or making corrections.

Should you have other questions or concerns about these privacy policies, please send us an email at [email protected]

Last updated: May 5, 2011