Privacy Policy

This privacy policy ("Privacy Policy") describes the ways we collect, manage, store, use, and protect the information, including personal information, and data that you provide or we collect in connection with FunGames' game application ( “Service”). By using our Service, you agree to the collection and use of your personal information as outlined in this Privacy Policy.

1. Applicability of our Privacy Policy

This Privacy Policy explains how we collect, use and protect your personal data. Please read this policy carefully to understand our practices regarding your personal data and how we will treat it.

Respecting and protecting your privacy and your personal data is very important to us. This Privacy Policy, together with our Terms of Service and any other documents referred to in it, sets out the basis upon which any personal data we collect from you, or that you provide to us will be processed by us or on our behalf.

By visiting our website and using our products and services (including, but not limited to, our iPhone apps, iPad apps or Android Apps and via mobile phone) you acknowledge the terms of this Privacy Policy and the use and disclosure of your personal data as set out in this Privacy Policy.

We will review this Privacy Policy periodically, and reserve the right to modify and update it at any time. You acknowledge that we may make changes to this Privacy Policy and you should check back to this page from time to time to review this Privacy Policy. Changes to this Privacy Policy will come into effect immediately upon such changes being uploaded on our websites.

2. How we collect your personal data and what we collect

We collect personal data about you in the following ways when you use our products and services. We collect information in the following circumstances:

• when you use our Game apps;

• when a user account is created and managed;

• when you connect your user account to your Facebook;

• when you participate in any interactive features of the Service; or

• when you otherwise communicate with us or via the Service.

When you access to our websites and our apps , we won’t collect your legally-sensitive data (i.e. race, ethnicity, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sexuality and/or criminality) and other sensitive data (i.e. child data, social security numbers, bank account or payment card details).

We may also employ third party ad-serving(including but not limited to Google, Facebook, Mopub and its affiliates) and/or analytics technologies(including but not limited to Tableau, Kibana and its affiliates) that may use various methods to collect information through our software and the Service. These technologies may be embedded within our software and the Service and may collect, amongst other things, the information below.

We may collect user’s data from you, which includes:

• your name, date of birth, email address, and personal description;

• demographic and location information as well as information from your device including but not limited to IP address, device UDID, IDFA, IDFV, Android ID, software, applications, hardware, browser information, internet usage information and in-game information;

• technical information such as the internet protocol (known as IP) address used to connect your computer to the internet, your log-in information, time of access, date of access, time zone setting, web page(s) visited, software crash reports, type and version of browser used, browser plug-in types and versions used, and operating system and platform to ensure the security of your account and to verify that the person operating your account is you;

• your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our websites and apps(including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call out customer service team; and

• in-game behaviors when you play a game, participate in discussions board or other social media functions, or when you report a problem on our websites or mobile apps.

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship. We will inform you if your failure to provide any requested personal information is going to result in these consequences.

3. Why we collect your personal data

1) General

We collect, use and disclose your personal data collected through our Service for a number of reasons, including:

● to carry out our obligations as a result of any contract entered into between you and us and to provide you with the information and services that you request from us;

● to notify you about changes to the products and services that we offer and (where you have indicated your consent) to directly market these products and services to you;

● to administer our websites for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

● to allow you to participate in interactive features of our products and services ;

● as part of our efforts to keep our products and services safe and secure;

● to measure or understand the effectiveness of our advertising and marketing;

● to operate and improve our products and services;

● to set up and maintain your registration with the Service;

● to improve customer service;

● to provide features available in the Service;

● to audit and analyze the Service;

● to ensure the technical functionality and security of the Service;

● to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;

● for statistical and research purposes (including market research, marketing and data analysis purposes);

● to ensure the effective operation of software and IT services procured by us (including disaster recovery);

● to comply with licensing and regulatory requirements that are applicable to us; and

● for other reasons with your consent.

2) Marketing

We (and permitted third parties, including but not limited to Google, Facebook, Mopub and its affiliates) may contact you for direct marketing purposes via social and direct messages, email, etc.

This marketing may relate to:

● products and services we (or permitted third parties) feel may interest you;

● information about other goods and services we offer that are similar to those that you have already used or enquired about;

● upcoming events, promotions and new products/services or other opportunities as well as those of selected third parties; and

● information regarding any applicable loyalty programs (including points earned and free, bonus and promotional points).

4. Who do we share your information with

We may share your personal data with the following categories of recipients:

1) selected business partners and advertising partners

Your personal data(e.g. advertising identifiers, such as IDFA and AAID) will be disclosed by us to our business partners and advertising partners, including without limitation, Google, Facebook (including their sub-contractors) who will use your data, amongst other things, to review and improve their products and services, to help them identify new products and services, for statistical analytical purposes and for the purpose of directly marketing their products and services to you, subject to you consenting to such marketing activities.

2) public authorities/ regulatory bodies/industry bodies

We may disclose your personal data:

• to regulators and law enforcement agencies;

• in response to an enquiry from a government agency.

3) service providers

We may disclose your personal data to third party service providers (including our professional advisors, data analysis processors and data storage service providers) who require access to such information for the purpose of providing specific services to us. These third parties will generally only be able to access your data in order to provide us with their services and will not be able to use it for their own purposes.

5. What are your rights?

You have various rights in relation to the data which we hold about you. We have set these out below.

The EU General Data Protection Regulation ("GDPR") gives you the following rights in relation to your personal data:

1) Right to object

This right enables you to object to us processing your personal data where we do so for one of the following reasons:

• because it is in our legitimate interests to do so;

• to enable us to perform a task in the public interest or exercise official authority;

• to send you direct marketing materials; or

• for scientific, historical, research, or statistical purposes.

2) Right to withdraw consent

Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

3) Data subject access requests

You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

4) Right to erasure

You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:

• the data are no longer necessary;

• you have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;

• the data has been processed unlawfully;

• it is necessary for the data to be erased in order for us to comply with our obligations under law; or

• you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

5) Right to restrict processing

You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

6) Right to rectification

You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

7) Right of data portability

If you wish, you have the right to transfer your personal data between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.

6. Security

We will take all reasonable precautions necessary to protect your personal data from

• loss, theft, misuse and interference;

• unauthorised access, disclosure, use or modification.

Such measures will vary depending on the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, organizational and electronic security measures.

This includes, for example, the protection of passwords using industry standard encryption, measures to preserve system security and prevent unauthorised access and back-up systems to prevent accidental or malicious loss of data. We may use third party data storage providers to store personal data electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment.

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet.

7. Children’s Privacy

This Service is not directed to children younger than thirteen (13) years of age. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not use the Service and do not send any information about yourself to us.

8. How long will we keep your personal data?

We will not keep your personal data for longer than is necessary for the purposes for which we have collected it, unless we believe that the law or other regulation requires us to keep it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements.

In general, we will retain your personal data for as long as we provide services to you and your account is active and following that period, for as long as we provide you directly with any other service offering.

When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. While we will endeavour to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.

9. Changes

We may update this Privacy Policy to reflect changes to our data and information privacy practices, so we encourage you to check this page periodically. We will try to notify you in advance where there are any significant or very important changes.