CONTENTS
1. Information We Collect
2. Information You Give Us Directly
3. Other Information We Collect When You Use Our Products
4. Information Provided to Us by Third Parties
5. How We Collect Information
6. Cookies and Similar Technologies
7. Analytics Technologies
8. Ad Serving Technologies
9. Fraud Prevention Technologies
10. How We Use Your Information
11. How We Process Your Information
12. Information We Share with Third Parties
13. International Transfer
14. How We Protect Your Personal Information
15. Age Guidelines and Children’s Privacy
16. Data Retention
17. Legal Basis for Processing (European Economic Area only)
18. Technical and usage Information
19. Advertising networks
20. Right to erasure
21. Right to portability
22. Right to withdraw consent
23. Right to object
24. Your Choices and Controls
25. Push notifications
26. AdChoices
27. Notifications regarding updates to the privacy policy
28. Contact Us
29. Customer Support
30. Privacy Inquiries
31. English Version Controls
Thank you for playing a Gaboom (“Actionist”, “we”, or “us”) game! Your privacy is important to us and we take our responsibility of caring for it seriously. This Privacy Policy describes what information we collect when you use our products. By using our products, you consent to this policy. This policy may change from time to time, so please review it frequently. Your continued use of Actionist’ products signifies your acceptance of changes to this Privacy Policy.
1. INFORMATION WE COLLECT
The information we collect depends on what products you use and how you use them. The controller of the personal information collected is:
Gaboom Studios LLC
2. Information You Give Us Directly
We collect information you provide us, including:
Information you provide when seeking help from us, such as your name, email address, and records of the issues you experience;
Information you explicitly provide us within the game for re-marketing purposes such as your name and email address.
Information you provide when completing a customer survey; and
Information you provide to enter a contest or sweepstakes. If you win, we may need to collect your social security number, postal address and/or national identification for eligibility, prizes delivery and tax purposes.
When you participate in social features through a Social Media Site, the information you disclose is public information. We may store and access it, and it may be read, copied, collected, or used by other users without your consent. Please make sure your privacy settings on the Social Media Sites you use reflect your preferences.
When you participate in online leaderboard components of our products, your in-game profile information, gameplay, and statistics may be visible to all.
3. Other Information We Collect When You Use Our Products
We collect other information directly or through third party analytics automatically when you use our products, including:
IP address;
Mobile and other hardware or device identifiers or the advertising identifier; (3rd Party)
Platform type; (3rd Party)
Your location, down to the resolution of city if you have provided permission; (3rd Party)
Information about your media, device, hardware and software, such as your hardware settings and components; (3rd Party)
Details about what Gaboom products you use and your use of them; (3rd Party)
Device event information, including crash reports, request and referral URLs and system activity details (e.g. whether you encountered an error playing our games or lost Internet access). (3rd Party)
We may also collect and store information locally on your device, using mechanisms like cookies, browser web storage and application data caches. (3rd Party)
4. Information Provided to Us by Third Parties
If you play or purchase our games or in-app purchases on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information may include your username and/or device identification number and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide, through systems such as Google Play Services or Apple Game Center.
We may receive information from third parties, like Facebook or other Social Media Sites, when you use these services in connection with our products. We may also receive information about you when other players choose to share their contact lists with us. We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. A representative list of these types of third parties can be found below. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.
5. HOW WE COLLECT INFORMATION
We collect some information from you when you provide it to us directly, such as via an in-game form or when you communicate with our customer support team. We and third parties also use certain technologies, described below, to deliver positive customer experiences.
Our products change over time and those changes are reflected in new versions that are available to download from the Apple App Store, Google Play Store, Amazon App Store, and other official stores. Gaboom recommends that you always use the latest version of our products to guarantee you have the most secure, privacy-oriented, and engaging experience possible.
Older Gaboom products may not provide all of the privacy protections discussed in this document. Your continued use of them indicates that you understand that your data may be collected by Gaboom and third party partners and that you consent to that collection.
Gaboom cannot guarantee the integrity of versions of products that are installed from unofficial channels and does not support provide customer support or provide privacy guarantees for those unofficial versions. If you are using a version of one of our products that was installed from an unofficial channel, we encourage you to remove it from you device as soon as possible and install an officially distributed version.
6. Cookies and Similar Technologies
We use cookies and similar technologies to help us understand things like what web pages, features, or ads you view and what games you play. This information helps us measure the effectiveness of our advertising, make sure you don’t see the same ad repeatedly and otherwise enhance your user experience. We use other technologies for similar purposes as a cookie, such as web beacons, pixels and other similar technologies. Your Internet web browser enables you to opt out of tracking with cookies. Please visit http://www.allaboutcookies.org or the documentation for your individual web browser if you would like to learn more about managing your cookie preferences.
We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our products, troubleshoot technical problems, detect and prevent fraud, and to enforce our Privacy Policy. Our legal basis for this collection and processing is to protect our legitimate business interests and therefore do not seek consent to collect your information for these purposes. You may contact gaboomgames100@gmail.com if you have additional questions about these use cases.
7. Analytics Technologies
We use our own game servers and internal and third party analytic technologies to collect information about how you use our products, your computer or device and the health of our products.
For example, Gaboom may collect and store data from your device when you use our products. This information includes technical and related information about your computer or device and operating system (such as IP address and device ID), information about your feature usage, gameplay and usage statistics and system interactions. If you play a game offline, this data will be stored on your device and may be transmitted to Gaboom when your device connects to the Internet. If you participate in online components of our games, such as leaderboards, Gaboom may also collect, use, store, transmit, and publicly display statistical data regarding game scores and achievements.
Third party analytics services integrated into our products may combine the information they collect in connection with Actionist’ services with information they have independently collected over time and across different websites and applications. Many of these companies collect and use information under their own privacy policies. A list of the third party analytics companies that operate in our products can be found in the Appendix below.
8. Ad Serving Technologies
Our products may employ ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies like identifiers to deliver offers to you. Some of these technologies can sync or connect behavior across different mobile apps, devices, and websites. The ads can be tailored to your interests. This is called interest-based advertising. For instance, you may be presented with an offer for a product we think you might enjoy. Or if you express interest in a game, you might receive an advertisement later for that game or similar products in Gaboom games or in different mobile applications or on websites. Other in-game advertising technologies enable advertising to be temporarily uploaded to your mobile device or web browser and later replaced while you are online.
These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to device advertising identifiers, this information includes:
Advertisements served and the location of the ad;
Length of time an advertisement was visible;
Domain type, IP address, size of the advertisement; and
Advertisement response.
Third party advertising companies may combine the information collected in the context of delivering an ad to you via our products with other information they have independently collected over time and across different products, websites, and services. Many of these companies collect and use information under their own privacy policies. A list of ad serving companies that operate their own networks in our games as well as how to opt out the extent applicable can be found below.
To learn more about some of these ad networks’ practices, see the Your Choices and Controls section below.
European Economic Area only. Prior to being shown ads in Gaboom products, you will be asked whether you consent to the tracking that enables personalized ads. You have the right to change your consent status at any point in time through the settings menu in the updated games. If you have questions about how to change your consent status or to inquire regarding your rights to erasure or data portability, please contact our privacy team at gaboomgames100@gmail.com.
9. Fraud Prevention Technologies
When you use a Gaboom product, we or third parties may use cookies and similar technologies, or collect data about your machine or device, for fraud prevention, security, and authentication purposes. Our legal basis for collecting and processing your information for these purposes, without your consent, is that we consider them to vital to protecting our legitimate business interests.
10. HOW WE USE YOUR INFORMATION
We use your personal and non-personal information, both individually and in aggregate, in the following ways:
To operate our business and to enhance and personalize your game experience, including to:
Operate, improve, and develop our games and services;
Populate online leaderboards and enable online challenges;
Help you find your friends or tell your friends about a Gaboom product;
Facilitate sharing on social networks;
Serve and measure the effectiveness of advertising;
Measure the health of our services;
Provide game experiences customized to your preferences;
Facilitate your gameplay on multiple devices, when available;
Identify, fix, and troubleshoot bugs and service errors;
Provide software updates;
Save game progress and stats;
Adhere to your preferences and to deliver dynamic content; and
Help keep our services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies.
To provide you support, including to:
Help identify and troubleshoot problems with your account or games;
To survey your opinions through surveys or questionnaires;
Communicate with you and respond to your specific requests or questions; and
Manage and send you confirmations and important information about your products.
To personalize our communications with you, including to:
Present offers or information relating to games you might like;
Make recommendations to you; and
Personalize advertising for you and deliver targeted marketing, service updates and promotional offers.
11. HOW WE PROCESS YOUR INFORMATION
Gaboom uses analytics services to understand how users engage with our products. Our analysis relies on your consistent device identifier, or identifier for vendor (IDFV) on Apple devices, so that we can track your behavior over time and develop an understanding of how you prefer to interact with our products. If you have more than one Gaboom product installed on your device, those products may share the same identifier value. This enables us to develop an understanding of how you engage with all of the Gaboom products you have installed. The identifier value is provided to Gaboom through the operating system on your device. In the course of processing your data, we may do any of the following:
Analyze your behavior in our products over time;
Analyze your behavior in aggregate;
Combine your information with the information of other players to create anonymized aggregate reports that allow us to understand large-scale behavior trends;
Analyze your information to understand how well our products perform on your device or to investigate bugs, crashes, and other technical issues;
Combine your information with the information of other players to create customer segments based on behavior in our products or location-based behavior;
Use analysis of your behavior in our products to provide you with customized gameplay experiences;
Use your device identifier to enroll you in an A/B test. An A/B test is a type of simple behavioral experiment wherein groups of users are provided with slightly different experiences in our products so that we can research and analyze which of the experiences is the most compelling to users of our products; and
Analyze your behavior in the context of an A/B test.
European Economic Area (EEA) Only:
Per requirements under the EU’s General Data Protection Regulation (GDPR), the ad networks we employ log your consent state for compliance purposes. This information is stored on their servers and is used solely for GDPR compliance. Your device identifier is stored along with your consent status. If you consent to personalized advertising, your device advertising identifier also is stored in case we need to be able to access it to assist you with data portability or erasure requests. Your device advertising identifier is not stored in the ad networks server if you do not consent to personalized advertising.
Please note that your advertising consent status is only respected when you are playing the game from within an EEA member country.
12. INFORMATION WE SHARE WITH THIRD PARTIES
We do not share personal information that directly identifies you (such as your name, email, or postal address) with independent third parties without your consent, unless it is required by law or we determine that disclosure is critical to protect our rights, property, or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.
If you contact us via gaboomgames100@gmail.com, your email will be processed through Google’s G Suite email service and forwarded to a support personnel for further processing.
We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys or analyzing gameplay event data. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.
We do not knowingly disclose personal information about children under 16 years of age to independent third parties even with consent.
However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.
We do not control information sent from the games to third parties, such as advertising networks and analytics companies that receive information in the normal course of your activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our products. An example is the Facebook “Like” button.
European Economic Area (EEA) Only:
We use your device settings and IP address to determine whether we believe you are located in the EEA. That processing is done on your device.
If your device indicates that you are located in the EEA:
Gaboom does not collect gameplay analytics from your device if:
You are of legal age to consent in your country of residence, we prompt you for consent to serve personalized advertising and you refuse
13. INTERNATIONAL TRANSFER
Personal information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which Gaboom, its business partners, or third party agents operate. By using our products, you consent that your personal information may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.
14. HOW WE PROTECT YOUR PERSONAL INFORMATION
We have put in place reasonable controls designed to help safeguard the personal information we collect via our products. However, no security measures are perfect and we cannot assure you that personal information that we collect will never be access or used in an unauthorized way.
15. AGE GUIDELINES AND CHILDREN’S PRIVACY
Protecting children’s privacy is extremely important to us. We also encourage parents and/or guardians to play an active role in their children’s online experiences at all times.
Gaboom' products are intended for general audiences and do not knowingly collect any personal information from children under the age of 16. If you are under 16 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access Gaboom' products. If you believe Gaboom has inadvertently collected such information, please contact us (information below) so we can promptly remove the information.
16. DATA RETENTION
Gaboom has a policy of retaining information we collect for no longer than 90 days. During the period when we hold Information, we may transform and aggregate it such that it no longer is personally identifiable. We may retain the de-identified aggregate data products for more than 90 days to support business critical needs.
Uninstalling Gaboom applications from your devices does not cause the data that we possess to be deleted. It remains subject to the same data retention and expiration policies.
17. LEGAL BASIS FOR PROCESSING (EUROPEAN ECONOMIC AREA ONLY)
If you are a resident of the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (i) we have your consent to do so, (ii) where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested), or (iii) where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests which are not already described in this Privacy Policy, we will make clear to you at the relevant time what those legitimate interests are.
18. Technical and usage Information
Gaboom does not collect in-game technical or usage data or gameplay analytics for players in the European Economic Area. Note that Google Play Services, Apple Game Center, and other platform-level services may collect gameplay analytics if you are located within the EEA. Please see your device-level settings for more information about how to disable those services. Gaboom considers any data specific to your use of our apps that is collected or processed through Google Play Services or Apple Game Center to be in our legitimate business interests.
19. Advertising networks
Gaboom works with advertising partners that may collect information from you as part of their process of serving advertisements in our products. This is described above in the section “Ad Serving Technologies.” In accordance with the General Data Protection Regulation (GDPR), Gaboom' advertising partners in the European Economic Area all function as independent data controllers. Prior to showing you personalized advertisements, you will be asked whether you consent to sharing your information with the advertising company. If you are a resident of an EEA country and indicate that you are below the age of 16, you will be served non-personalized ads and the advertising companies will not collect personal information from you.
20. Right to erasure
Under the GDPR you have a right to have Gaboom and our third party partners erase the personal information we have collected from you without undue delay.
21. Right to portability
Under the GDPR you have a right to request a copy of the personal data Gaboom and our third party partners have collected from you.
22. Right to withdraw consent
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time by going to the settings page and selecting “Non-Personalised Ads” Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at gaboomgames100@gmail.com
23. Right to object
Under the GDPR, you have the right to object to the processing of your data. If you wish to object to the processing of your data, please contact us at gaboomgames100@gmail.com
24. YOUR CHOICES AND CONTROLS
1. Push notifications
If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device and game.
25. AdChoices
For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative https://www.networkadvertising.org/ and/or the DAA Self-Regulatory Program for Online Behavioral Advertising https://www.aboutads.info/principles. To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please download the version of AppChoices for your device here http://youradchoices.com/appchoices or visit these websites:
Welcome
https://www.youronlinechoices.eu
Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.
26. NOTIFICATIONS REGARDING UPDATES TO THE PRIVACY POLICY
From time to time, we may update this Privacy Policy. We will notify you about changes to this Privacy Policy by placing a notice in our products and/or on our company website. We encourage you to periodically check back and review this policy so that you always know our current privacy practices.
27. CONTACT US
1. Customer Support
You can contact us for any queries at gaboomgames100@gmail.com
1. Privacy Inquiries
You can contact us for any queries at gaboomgames100@gmail.com
28. ENGLISH VERSION CONTROLS
Non-English translations of this Policy may be provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
APPENDIX: OUR AD SERVING AND ANALYTICS PROVIDERS
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This table summarizes our ad serving and analytics providers and where you can go to get more information about their policies and practices and opt out of their networks in many cases.
* Indicates a company or service whose software may be integrated in older versions of Gaboom products but are not present in versions released after May 2017.
• AdMob Advertising
https://policies.google.com/technologies/ads
data-protection-office@google.com
— AdMob Partners
https://support.google.com/admob/answer/9012903
Note that, at this time, AdMob may serve ads from any of these providers in the EEA through its mediation network.
data-protection-office@google.com
• Google Analytics for Firebase
https://cloud.google.com/terms/data-processing-terms
https://support.google.com/cloud/contact/dpo
• Unity Advertising
https://unity3d.com/legal/privacy-policy
privacy@unity3d.com
• Ironsource
https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/