We posed these questions to Zynga:

1.

Can you opt out of disclosing your Personally Identifiable Information (PII)?

Yes. Zynga offers functionality that lets you opt-out of public indexing of your public profile information. Further, you can opt in to receive information from a third party.

2.

Who is your Personally Identifiable Information (PII) disclosed to?

Zynga will provide information to third party companies to perform services on their behalf (e.g. payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts). Moreover, in most Zynga games, a user’s social networking service friends will see their name, profile photo and descriptions of game activity. In many Zynga games friends and players will be able to see user’s game profile, which may include name and profile photo, which in certain cases can reveal your social networking service User ID number or Zynga ID.

In addition, the company may share aggregated information (non-PII), and technical information (including IP addresses, MAC addresses) with third party advertisers. Advertisers may also collect this information through tracking technologies like cookies and web beacons. The company also notes that “Your information, and the contents of all of your online communications (including without limitation chat text, voice communications, IP addresses and your personal information) may be accessed and monitored as necessary to provide the Service and may be disclosed” when: required in response to legal process, to satisfy any applicable laws or regulations, when the Service is being used in the commission of a crime, when there is an emergency that poses a threat to the health/safety of user, another person, or public, and in order to protect the rights or property of Zynga.

Finally, in the event that Zynga undergoes a business transition, PII may be a portion of the assets sold.

3.

Does the privacy policy involve self-regulation or a seal of approval?

Yes; it self-certifies that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. TRUSTe’s Privacy Seal.


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