Background
The privacy of your personal and non-personal information is afforded the highest level of importance by Fine Click Apps.
We will strictly comply with all relevant legislative requirements, and, in the event of any inconsistency, the legislative requirements will override the provisions of this document.
We reserve the right to amend our Privacy Policy at any time without notice to you, and such amendments will take effect from the date of issue on our website.
If you are a minor at law (which usually means you are aged under 18 in countries including Australia and the United States, though this age may vary depending on where you are located), you must get your parent or guardian’s permission before providing us with any personal information. We may collect Non-Personal Information, such as a device ID or other persistent identifier linked to the device or computer, which may be used by a child to play our Websites/Apps.
Use of information – purpose and legal basis
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
Age
-is being processed:
a. To identify whether you are a child or adult for data protection purposes to determine the legal requirements for our processing of your data.
Our processing for the above purpose is necessary for compliance purposes, see Article 6(1)(c) of the GDPR.
Log-, device-, usage-, and consumption information
-are being processed:
b. To provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
c.to provide and maintain the App and the game experience; and
d.to send you technical notices, updates, security alerts, and support and administrative messages;
Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.
e.to provide news and information about the App that we think will be of interest to you;
f.to personalize and improve the App and provide tailored content and features;
g.to monitor and analyze trends, usage and activities in connection with the App; and
h.to provide children (as this term is construed under GDPR in EU, COPPA in the US and relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in the App.
Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").
i.to provide non-child users that have given us consent to share their advertising IDs with our ad network partners (as further specified under Sharing of Information) for the purpose of serving them with personalized advertisement in the App (behavioral advertising).
Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).
Information from other sources
-are being processed:
j.to provide and deliver the products and services you request and send you related information;
Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.
Sharing of information
We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the advertising network companies.
k.to link or combine information we get from others to help understand your needs and provide you with better service; and
l.to provide news and information about the App we think will be of interest to you;
Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR.
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
Your rights
If you wish to use any of the rights described below, you may contact us at any time by emailing us.e process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
Right to request access
You have the right to request access into the data that we are processing on you, see
Article 15 of the GDPR, including information about:
•the purposes of the processing
•the categories of personal data concerned
•the recipients or categories of recipient to whom the personal data have been or will be disclosed
•the envisaged period for which the personal data will be stored
Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.
The right to object
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the App will cease automatically.
Right to rectification and erasure
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:
•the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
•if you have withdrawn your consent and there are no other legal grounds for the processing,
•if you have objected to the processing and there are no overriding legitimate grounds for the processing,
•the personal data have to be erased for compliance with a legal obligation in Union or Member State law,
•the personal data have been unlawfully processed or
•the personal data have been collected in relation to the offer of information society services.
Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
The right to restriction
You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest
The right to withdraw consent
If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
Please note that if you withdraw your consent, your user license to use the App will cease automatically.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
Collection of Information
We will only collect information Personal and non-personal where it is reasonably necessary to do so for the conduct of our business. Any collection of personal information by us will be fair and lawful and will not be intrusive.
We may collect information regarding your use of our software, applications and/or services, including information about the duration of your use, the features you use and your interactions with other users of the software, applications and/or services.
We may collect information regarding the device you use to access the software, applications and/or services, including (where applicable) its model, operating system, screen resolution and other technical information.
We may collect any Personal Information that you disclose when you choose to send a message to another user or defined group of users through our message, chat, post or other in-game function as well as the necessary Personal Information of the user(s) you are contacting, in order to facilitate the communication. (We will never collect any information sent outside of the functionality of our Websites/Apps, including through emails or text messages).
We collect personal information that you provide directly to us such as at the time of account creation, managing your profile, marketing communication, using any interactive and engaging feature of our service, promotional survey, communication with our customer support team otherwise communicate with us. Your personal information may include your name, email id, password, postal address, photographs, comments and posts on our forum, messages between different users and any other personal and contact information that you may choose to provide.
We collect information when you make a purchase through our Apps, we will collect your credit card information and other billing information.
If you choose to submit your Personal Information to us for any other reason in any other form, we will collect such Personal Information and use it for the purposes for which you submitted it.
We will not collect any Personal Information from you simply by virtue of your visiting our Website; we only collect it if you choose to submit it to us. We do, however, collect Non-Personal Information such as device IDs, IP addresses and other persistent identifiers, as well as Usage Data, whenever you use our Website/Apps. Such Non-Personal Information is not combined with Personal Information unless you choose to submit Personal Information to us.
Use and Disclosure of Information
In general, we will not use or disclose personal information about you otherwise than for the purpose of providing or offering goods and services to you, for any other purpose that you may reasonably expect, for any other purpose authorized by law, or for any other purposes disclosed to or authorized by you. This may include disclosures to organizations that provide us with professional advice, such as solicitors, accountants and business advisors.
It may be necessary for the information to be disclosed to other organizations in the course of our provision of services, or for the conduct of our business. These other organizations may include other parties involved in the provision of services to you, our business partners involved in the software, applications and/or services we provide to you, and other organizations providing services to us, such as payment processors or hosting services. We direct all such organizations to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on our behalf or to us.
We may use your personal information to provide you with any goods, services, or functionality you have requested; to respond to any inquiries you have made through our customer service features, to send you newsletters, promotions or marketing materials. We will provide you with the opportunity to opt out of receiving such materials in the future. You may also opt out of receiving such materials at any time in accordance with the instructions provided in this Privacy Policy.
Non-Personal Information may be used by us for administrative, analytical, statistics compilation, research, optimization, security and other purposes. Specifically, we may use your Non-Personal Information to respond to customer service inquiries and to protect against cheating, crime or fraud or for other security reasons and for providing you advertising that better suits your interests. We may collect your Non-Personal information to track your use of our Websites/Apps to help us learn more about your gaming activities and understand your preferences and tendencies so that we can personalize your experience, provide you with in-game offers and notifications that are tailored to you, and otherwise enhance your gaming experience.
We may use information held about you to verify your compliance with any terms and conditions that may apply to the use of our software, applications and/or services.
The precise information required to be provided will vary depending on the circumstances requiring disclosure of that information.
Any personal information submitted to us online, including via the software and/or services, may need to be processed by a third party. By submitting personal information online or via the software and/or services, you consent to the disclosure of that information to a third party, who may be located overseas, for the sole purpose of processing the submitted information.
Below are provider names of some of the third party analytics and advertising services we use. Please see the links below to learn more about the privacy policy of our third-party service providers.
• Admob: https://www.google.com/policies/privacy
• Unity Ads: https://unity3d.com/legal/privacy-policy
Advertising
By using our Website/Apps, you may be offered advertising content. We or the ad networks we use may utilize ad-serving technologies that use cookies, beacons, tracking pixels and other technologies that are placed within the ads and allow us or our networks to collect Non-Personal Information. Non-Personal Information such as age and gender may be used to ensure that appropriate advertising is offered to you. Usage Data and Non-Personal Information such as advertising identifiers may be used to determine how many clicks an ad received, to measure the effectiveness of ad campaigns, to determine the proper amount of repeat views of a given ad, and/or to deliver ads that best relate to your interests. Depending on your device and its operating system, you may be able to choose to prevent your device’s ad identifier being used for interest-based advertising or reset your device’s ad identifier by changing the settings of your device.
Transfer of Information Overseas
You expressly agree that we may transfer and store your information on servers and equipment located in any territory, including, without limitation, Australia and the United States of America etc.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
1. Internal record keeping.
2. We may use the information to improve our products and services.
Security
We are committed to ensuring that your information is secure. In order to prevent any misuse, theft, loss, alteration, destruction, unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
For better user experience, we may get the following information
1. Demographic information such as location, preferences and interests for Re marketing purposes
2. Your public information if social media is used in the app.
3. App Usage Data and User Behavior