GRAB PRIVACY AND INFORMATION SECURITY POLICY
Effective Date: September 05, 2007
This Privacy and Information Security Policy ("this Policy") discusses the personally identifying information ("PII") that we collect about you when you use our website http://www.grab.com/ (the "Site") and the software, games and other services we provide on or through the Site (together with the Site, the "Service").
Who We Are. We are Grab LLC ("Grab," "Grab.com," "Site," "Service," "we," "us," or "our"). Grab.com is a popular place to access hundreds of great games, post content and to share ideas with others. In conducting our business, as further described below, we collect information, including PII, about the individuals who use the Service.
BY PROVIDING PII OR OTHER INFORMATION TO US OR BY USING OUR SERVICE, YOU AGREE TO THIS POLICY AND THE PRACTICES DESCRIBED IN THE POLICY.
1. INFORMATION YOU GIVE US
1.1 The Types of Information Grab Collects. We collect any information you enter on the Service or give us in any other way (such as through an email, survey, or letter). The information that we collect varies depending upon how you use our Service. Our Account registration process requires that you provide us with your user name, birthday and e-mail address, and that you create and provide us with a password. We may also request other information, such as your actual first and last name, gender, and zip code.
1.2 Information in Public Areas of the Site. Please keep in mind that whenever you voluntarily provide information in public areas of the Service, such as the user profile pages or forums, that information can be viewed and possibly used by others. We therefore advise visitors not to disclose contact information, including phone number, email address, street address or instant messenger address (within these public areas) that they do not wish to share. We are not responsible for PII you choose to submit in these public areas. Also, we may highlight content you post to the public areas of the Service such as reviews or comments, such as by featuring your content on the Site's home page.
2.AUTOMATIC INFORMATION COLLECTION
2.1 Cookies. Like many Web sites, we use "cookies". Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser. We use persistent, identifying cookies to remember your information and to link your activities to you. While you can take steps to warn of, block or disable cookies, if you do, the Service may not function and appear as we have designed it. Nonetheless, if you want to take these steps, you can do so by following the instructions associated with your browser. Our cookies do not collect PII that you provide to us during the registration process, but they do collect other information such as:
- (a) the domain name and host from which you access the Internet and the Internet address of the site from which you direct-linked to ours;
- (b) the date and time you access the Site and pages you visit;
- (c) your computer's IP address and information about its operating system, platform and the Web browser type and version you use;
- (d) demographic and other non-personally identifiable profile information about you; and
- (e) information to combat fraud or misuse.
2.2 Pixel Tags. In our e-mails to you, we use "pixel tags" to determine if your email software or service can display html-formatted e-mail (this helps us optimize the size of our e-mail messages and conserve bandwidth).
2.4 Promotions, Sweepstakes, and Contests. From time to time, we may host a promotion, sweepstake or contest on the Service. You may be asked to provide personal information or permit the transfer to a third party of your personal information in connection with such promotion, sweepstake or contest. It will be disclosed at the point of collection or transfer who is collecting or transferring the information and whose privacy statement applies, and it will be your choice whether or not you wish to permit such transfer to or collection of personal information by a third party.
3. GRAB'S USE AND RETENTION OF YOUR INFORMATION
3.1 Use of PII. We use your PII for such purposes as responding to your requests; monitoring and providing the Service; maintaining your Grab account; providing you with advertising and non-advertising content that we believe would be of interest to you; enforcing our rights and the rights of third parties, and investigating and ensuring compliance with the Terms http://www.grab.com/site/?page=termsofservice. We also may use your PII to contact you regarding your account, such as to inform you that you have received an email from another Grab member, or to forward to you user comments about the content you have posted. We may also email Grab messages of the day, newsletters, and similar communications about the Service.
3.2 Use of Other Information. We use non-PII for purposes such as measuring the number of visitors to sections of our Site, making the Service more useful to visitors and delivering targeted advertising and non-advertising content. We use IP addresses to analyze trends, administer the site, track a user's movement, and gather broad demographic information for aggregate, nonpersonally identifiable use.
3.3 Retention of Information. We retain information for as long as required, allowed or we believe it useful, but do not undertake retention obligations. We may dispose of information in our discretion without notice, subject to applicable law that specifically requires the handling or retention of information. You must keep your own, separate back-up records.
4. GRAB'S SHARING OF INFORMATION
Grab shares information with third parties, but only as described in this Section 4.
4.1 Advertisers and Others. We share non-personally identifiable information with advertisers, service providers, and other persons with whom we conduct business.
4.2 Service Third Parties. We contract with affiliated and non-affiliated third parties to provide services to us or to you on our behalf. Examples include providing marketing assistance, providing customer services, sending Grab email to you, removing repetitive information from customer lists, and analyzing data. These third parties have access to personal information needed to perform their functions.
4.3 Business Transfer. As we develop our business, we might sell or buy businesses or their assets, or engage in acquisitions, mergers, restructurings, changes of control, or similar transactions. In such transactions, customer information generally is one of the transferred business assets, and your PII is subject to such a transfer. Also, in the unlikely event of a bankruptcy, customer information may be transferred to a bankruptcy trustee or debtor in possession and then to a subsequent purchaser.
4.4 Compliance and Safety. We may release PII when we believe release is appropriate to:
- (a) comply with applicable law, and to respond to legal process, including subpoenas, search warrants and court orders, and to respond to or otherwise address written complaints of copyright infringement;
- (b) make disclosures under programs intended to prevent potential crimes or investigate persons;
- (c) enforce or apply agreements, including the Terms; or
- (d) protect the rights, property, or safety of Grab, our users, or others, including exchanging information with other companies for fraud protection and credit risk reduction.
5. INFORMATION SECURITY
5.1 Your Obligations. You must protect against unauthorized access to your password and to your computer. Please sign off when finished using a shared computer. Your e-mails to us are not necessarily secure against interception so do not include sensitive information in them - we generally will not ask for passwords in an email and you should assume that if you get such a request, it might be fraudulent. YOU MUST DO WHAT YOU REASONABLY CAN TO ENSURE THE SECURITY OF YOUR PERSONAL INFORMATION.
5.2 Our Security Measures. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. HOWEVER, WE DO NOT GUARANTEE SECURITY. Neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. If applicable law imposes any non-disclaimable duty (if any), you agree that the standard used to measure our compliance with that duty will be one of intentional misconduct.
The Service contains links to other sites. We are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of every web site that collects your personally identifiable information. This Policy applies only to information collected by the Service.
We reserve the right to send you customary business communications such as acceptance/rejection notices regarding content submissions, general system and administrative messages, address confirmations, and transactional information about your account, and we may not offer you the opportunity to opt-out of receiving such communications. However, we provide you with the opportunity to elect not to receive other types of communications, such as friend requests or the Grab of the day emails. If you want to stop receiving these communications, you may opt by going to the Profile tab on the Site and editing your email preferences.
8. ACCESS AND RECORD KEEPING
Information relating to our programs is not necessarily maintained in a retrievable form. However, you may make changes, corrections or updates to some PII provided through the Service which we use for communications with you, by going to the " Profile" tab on the Site. We may keep a record of all information that is changed. We may determine what may be changed. For example, if we are required to keep track of certain kinds of transactions, you may be prevented from changing relevant information.
9. CONDITIONS OF USE, NOTICES, AND REVISIONS
9.1 Privacy Concerns. Your use of the Service and any dispute over privacy is subject to the Terms http://www.grab.com/site/?page=termsofservice. If you have any concern about privacy at Grab, please send us a thorough description by using the contact support form at http://www.grab.com/site/?page=contactus, and we will try to resolve it. If you think we are in default of the Terms, you may contact us at Our Legal Notices Address in Section 10 below.
9.2 Notice Required by Law. In those jurisdictions that permit email notice, if we are required to disclose or provide notice of invasion of certain security systems, we will do so by email to the most current email address provided by you to us. It is critical that you keep your email contact information correct and updated with Grab at all times.
9.3 Identity Theft. If you believe that you are a victim of identity theft entitled by law to request information from us, write us at our Legal Notice address (see the next section of this Policy) and we will let you know what additional information you must provide to us. After we have received that information, we will supply without charge the information legally required to be disclosed that we then have, subject to applicable law and reserving all of our rights and defenses.
10. CONTACT INFORMATION AND INFORMATION ABOUT ENFORCEMENT OF OUR POLICY
Contacting Us & Our Address for Legal Notices; Notices to You. For customer service matters (including questions relating to this Policy), you may contact us by using the contact support form at http://www.grab.com/site/?page=contactus. To send us a legal notice, mail it by certified mail (return receipt requested) to: Legal Department, Grab LLC, 1100 Glendon Ave, Suite 800, Los Angeles, CA 90024. When we need to contact you, including when we give a legal notice, we may do so to a email address that we have on file for you or to your Grab email account, or we may post notice on the Site. You must keep your email address information accurate. If we make a material change to this Policy, we will notify you by posting notice to the Site for at least 30 days and sending you an email to your Grab email account or to the non-Grab email address that we have on record for you.
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