Welcome to Intelweb Ltd.’s (“Intelweb” or “we” or “us” or “our“) Privacy Notice!
This Privacy Notice describes how we and our affiliates collect, use, process, transfer and share Personal Information (as defined below) that we collect about you.
This Privacy Notice applies to all of our Games, whether played on our mobile applications or on other platforms such as Facebook. It also applies to our advertising activities on all platforms as described below and the Services that we may provide to you from time to time.
For information collected under this Privacy Notice, the data controller is Intelweb Ltd. Our registered office is Taman Pertama Ipoh Perak Malaysia, and our registration number 515059236.
Privacy Notice Key Points
The following key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
- Personal Information we collect. When you register, we collect your basic profile information from Facebook and/or any other third party log-in service and/or app store and/or play store and/or the Amazon Appstore, or any other store we may offer our Games and Services on. We also collect information about your use of the Games and/or Services. If you contact us for questions or complaints, we will collect the information related to your inquiry. It is your voluntary decision whether to provide us with any Personal Information (as defined below), but if you refuse to provide such information we may not be able to provide you with the Services.
- Basis for processing your Personal Information. Processing your Personal Information is necessary for the performance of the Terms and the provision of the Games and Services to you. Processing for the purposes of developing and enhancing new games, products and services, for analytics and statistical information, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
- Use of your Personal Information. We use your Personal Information mainly to administer and provide the Games, and Services, contact you with administrative information, contact you with marketing offers (if you indicated your desire to receive those), and improve the Games, and Services.
- Sharing your Personal Information. We may share your Personal Information with our service providers and subcontractors who assist us in the internal operation of the Games, and Services and process the Personal Information on our behalf and under our instructions as well as with our business partners and affiliates who may offer you products and services, based on your preferences (if you indicated your desire to receive these).
- We implement industry-standard measures to reduce the risks of unauthorized access or use of Personal Information, however, such measures may not provide absolute information security.
- Your rights. Subject to applicable law, you may have a right to access, update or delete your Personal Information and obtain a copy of the Personal Information we have collected about you. You also have the right to object to certain processing, including the right to object, at any time, to process your Personal Information for marketing purposes.
- We retain information for as long as necessary for the purposes set forth in this Privacy Notice.
- Changes to the Privacy Notice. We may change this Privacy Notice from time to time – in which case, we will post the updated Privacy Notice on this page.
Information we collect
“Personal Information” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
It is your voluntary decision whether to provide us with any Personal Information, but if you refuse to provide such information we may not be able to provide you with the Services.
Depending on which of our Games and/or Services you interact with, we may collect and process the following types of information:
- details about how you use and interact with our Games, Services and advertising, including any User Content you may upload to the Games;
- information that you provide us with when you fill out forms, answer questions or complete surveys when using any of our Services, when you create an account with us or if you invite your friends, via Facebook or WhatsApp, to use our Games and Services;
- if you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence;
- information we receive when you visit our website;
- information we receive when you subscribe to our newsletter
- your interactions with us on social media channels;
- information we collect via cookies and other similar technologies, as explained further below;
- information we collect when you use our Games and/or Services by logging in through Facebook, Google Plus and/or any other third party login service, including the app store used to download the Games. Please check such third party login’s policies in order to understand what information we receive and/or share. If you use our Services through Facebook, we may also collect your name and e-mail address associated with your Facebook account;
- information we collect about you from third-party companies and business partners (including publishing partners, platforms, advertising platforms and partners and data aggregators) which may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use this information as described in this Privacy Notice subject to any limitations herein of the company that collected the information from you; and,
- information automatically gathered from you about your computer, mobile device, operating system, IP address, device identifier, (geo) location, which may be shared with our service providers, affiliates, and business partners, what device you use to access our Games and Services, your operating system and browsing history or details regarding profile visits, as detailed in the section “Multiple Devices”, below.
Third Party Account Login
You can choose to log in with your Facebook account or another social network or third party account. Depending on your setting, we will receive some of your Facebook or other social network or third party login account information and may be able to offer you additional functionalities, including inviting friends, seeing their Game progress and private messaging with other players. In addition, you will be able to log in on multiple devices and synchronize your progress in our Games, across multiple devices on multiple platforms.
How We Use Your Personal Information
We, our vendors, business partners, service providers and subcontractors may use your Personal Information for a number of purposes. These include: (i) providing our Games and other Services to you (including storing your progress through our Games); (ii) optimizing and conducting analyses to improve the Games and Services we provide and developing new games and services; (iii) enabling in-app purchases and social network integration; (iv) providing customer support; (v) providing you with customized content and targeted offers, and advertising on the Games and/or Services, on other third-party sites or apps you may visit, or via e-mail; (vi) using your Personal Information for reviewing the usage and operations of our Games, and Services; (vii) using your Personal Information in an aggregated, non-specific format for analytical purposes (as detailed below); (viii) preventing fraud, protect the security of our Games, and Services, and address any problems with the Games and/or Services; (ix) maintaining records (subject to applicable law) and protecting our legal rights.
By analyzing all information we receive, including all information concerning users (including Personal Information), we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Certain shared Statistical Information is anonymous and aggregated, while certain Statistical Information may be individualized. We may share such Statistical Information, either anonymized or individualized, with our partners, without restriction, on commercial terms that we can determine in our sole discretion. We may provide information that we receive to Google Analytics (as more fully detailed below) in order to receive an analysis of the use of our Games, and Services.
We may use your Personal Information to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example, to track potential problems or trends with our Services, or to test out new Game features and content.
We may use your data as required or permitted by any applicable law.
Advertising and promotion
We may process your Personal Information in connection with advertising and marketing, including by way of automated decision making. You are entitled to opt out of such processing for marketing purposes. This includes using Personal Information that we have about you, including advertising-specific device IDs and the Games you play, to try to make sure you only see advertising that might be of interest to you. We may also use Personal Information that we have about you to help a third party deliver advertisements that are tailored to you based on a determination of your characteristics or interests by us based on the information that we have about you. In order to opt-out of seeing personalized ads from our business partner Google, please follow the directions detailed in this short article: https://support.google.com/ads/answer/2662922?hl=e.
These advertisements may be shown within our Games or within websites and other media which are published by others and optimized by us or using our information. This is done using anonymized information. We will not sell any of your personal information to third party advertisers.
We will also use Personal Information about your mobile device in order to measure the effectiveness of our ad campaigns and we may also retain information about how many times you have seen a particular advertisement so we can stop you from seeing it too many times.
Cookies, Ad Identifiers and Similar Technologies
Advertisers on mobile devices may use advertising (or ad) identifiers (non-permanent, non-personal device identifiers such as the Android advertising ID and/or Apple’s ID for advertising, or IDFA) to enable and optimize their advertising. You can reset these identifiers or indicate your preference that they should not be used for advertising purposes, as detailed below.
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.
By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device.
Adjusting your preferences as described in this section does not mean you will no longer receive advertisements, it only means the advertisement you do see will be less relevant to your interests.
Who We Share Your Personal Information With
We may share your information, including Personal Information, as follows:
- with our trusted service providers, business partners, affiliates, and subcontractors, who may use such information to: (1) help us provide you with the Games and Services; (2) aid in their understanding of how users are using our Games and Services; (3) provide to you direct marketing, promotional materials and targeted offers and advertising relating to our Games and Services or related products or such third party’s services and products, as detailed in this Privacy Notice.
- We may use third-party advertising partners, including ad exchanges, ad networks and ad servers when we advertise our Games in services or media published by other companies. Our advertising partners help us to serve advertisements to you. Some of this technology also helps us to make decisions as to whether or not to show a particular advert to you – for example, by informing us that you have shown an interest in similar goods or services previously. In addition, if we place cookies, as permitted hereunder and subject to applicable law, we may share such information with our advertising partners. Our advertising partners may collect Personal Information about you when you use our Games and/or Services or the services of others. This Privacy Notice does not apply to the collection of your information by our advertising partners, and we, therefore, recommend that you review their privacy policies for more information. You can find out more in “How to adjust your preferences” above.
- where it is necessary to carry out your instructions relating to the Services;
- where your data is on an anonymous and aggregated basis, meaning you could not be personally identified from it;
- when you interact with us, including through our social media channels or add User Content to any Game;
- when required by law, regulation subpoena, court order or other law enforcement related issues or as is necessary to comply with any legal and/or regulatory obligation. In doing so, we will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content of any user, including in the event of a user suspected to have engaged in illegal or infringing behavior.
- in order to enforce or apply our terms and conditions, this Privacy Notice and/or any other agreement with you; or to protect the rights, property, or safety of Ilyon, our users, or others;
- we may transfer our databases containing your Personal Information if there is a sale of the assets of Ilyon or corporate restructuring, or as a result of a change of control of Ilyon. Such third party to which Ilyon transfers or sells Ilyon’s assets will have the right to continue to use your Personal Information, provided to us as set out in this Privacy Notice.
We may use subcontractors and service providers who are located in countries other than your own and send them information we receive (including Personal Information). All our subcontractors will be subject to (i) non-disclosure and non-use obligations; (ii) agreements ensuring the same level of data protection as described in this Privacy Notice.
How We Protect Information
We make efforts to follow generally-accepted industry standards to protect the Personal Information submitted to and collected by us, both during transmission and once we are in receipt of such information. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Your Rights Concerning Your Personal Information
You have certain rights in relation to the Personal Information that we hold about you, as follows detailed below. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
- Right of access and data portability. You have a right to know what Personal Information we hold about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Information you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request us to) transmit such Personal Information to another party. If you wish to exercise this right please contact us letting us know what information, in particular, you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide all the information you ask for, for instance, if the information includes Personal Information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
- Right to correct personal information. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Information and/or have us suspend the use of Personal Information, the accuracy of which you may contest, while we verify the status of that Personal Information. We will correct your Personal Information within a reasonable time from the receipt of your written request thereof.
- Deletion of Personal Information. In certain circumstances, you have a right to have Personal Information that we hold about you deleted. Should you wish to have any Personal Information about you deleted, please contact us using the information below. Subject to applicable law, we will delete Personal Information provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected information. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Information, you should also delete our Games from your mobile devices and terminate your account with us and clear our cookies from any device where you have played our Games. We may retain certain Personal Information (including following your request to delete) for audit, record-keeping purposes, as permissible by applicable law as well as other purposes, permissible under applicable law. We may also retain your information in an anonymized form.
- Account deactivation. You can ask us to deactivate your account by contacting us using the information below. In order to deactivate your account, we may ask you for additional information. You may choose to disassociate your Facebook account from our Games and delete our Games from your mobile devices.
- Direct marketing opt out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. If you do, please notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however, it may take a few days for us to update our records before any opt-out is effective.
- Right to object. Subject to applicable law, you may have the right to object to processing of your Personal Information, including, for the purpose of direct marketing.
- Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.
We may send you e-mail or other messages and/or a newsletter about us, or our Games and Services. You may remove your Personal Information from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by contacting us, using the information below. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send, as well as through your account settings on the mobile application. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your activities, purchases, and transactions on the Games, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may delete the Games from your device.
We will keep your information for as long as we consider necessary for the purposes described above, or as long as the permitted by applicable law. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.
Links to Third Party Websites and Services
You must be at least 16 years old (or any other age permissible by applicable law) to access and/or use our Games and/or Services. We do not knowingly collect Personal Information (as defined below) about children under the age of 16 (or any other age permissible by applicable law). In the event that you become aware that an individual under the age of 16 (or any other age prohibited under applicable law) has enrolled without parental permission, please advise us immediately.
Changes to the Privacy Notice
By using the Games and/or Services, you signify your assent to the terms of this Privacy Notice.
We may update this Privacy Notice from time to time – we encourage you to review it periodically. By continuing to access or use the Games and/or Services after those changes become effective, you agree to be bound by the revised privacy notice. If you do not agree with the terms hereof, please do not use, install or access the Games and/or Services. The Privacy Notice may change over time, in which case, we will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.
If you want to contact us about any of the matters in relation to this Privacy Notice, including to exercise any of your rights, then please contact our customer services department by emailing firstname.lastname@example.org.
Last updated April 2018.