PRIVACY POLICY

[Last Modified: Sep 1, 2020]

INTRODUCTION

Bubba Games (“Bubba Games”, “we”, “our” or “us”) respects the privacy rights of our online visitors and mobile customers and recognizes the importance of protecting the information collected about you. For our practices regarding children, please see below. Travel Market LTD is the direct owner of the developer account Bubba Games

ABOUT THIS PRIVACY POLICY

This Privacy Policy (the “Privacy Policy”) applies to the collection, use and disclosure of personal and non-personal information by Bubba Games and its affiliates through the y1y.org website (the “Site”) and the mobile apps published by Bubba Games (the “Apps”) (in this Privacy Policy, the Site and the Apps are referred to collectively as the “Platforms”). This Privacy Policy does not apply to the collection, use or disclosure of personal and non-personal information through any apps for which Bubba Games is not the publisher.

By using the Platforms, you signify your assent to our Privacy Policy. If you do not agree to this Privacy Policy, please do not use any of our Platforms.

We reserve the right to make changes to this Privacy Policy at any time. Please check the Privacy Policy each time you use our Platforms to ensure you are aware of any changes in our privacy practices. Our Privacy Policy will indicate the date it was last updated. Your continued use of our Platforms will signify your acceptance of the changes to our Privacy Policy. If there is a substantive or material change in the way that we use your personal information, we will notify you via email of the relevant changes or provide other prominent notice. If you choose to opt-out of or not opt-in to our changed practice, our email communication (if applicable) will contain instructions on how to do so. If such change affects children users, we will first notify and obtain the prior verifiable consent of a parent or legal guardian.

HOW WE PROTECT THE ONLINE PRIVACY OF CHILDREN UNDER 13

Bubba Games takes many precautions to protect the online privacy of children. Whenever we refer to “children” in this Privacy Policy, we mean children under the age of 13. Please help us in protecting children’s privacy by instructing them to never provide any personal information (full name, email address, home address, phone number, etc.) without your permission.

Bubba Games follows the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children, in our online services and Apps that are directed to children. If you would like to learn more about COPPA, you can refer to the “Children’s Privacy” section of the Federal Trade Commission’s website.

Currently, Bubba Games does not knowingly collect any personal information from children or within the child-directed portions of our Platforms except as otherwise outlined in this Privacy Policy. If we were to collect and store personal information from children, we would obtain the consent of a parent or legal guardian before such collection, unless the collection of information falls within an exception that is permitted under COPPA.

In our Apps directed to children users, we collect information which includes persistent identifiers such as a device identifier (“device ID”) or an Internet Protocol address (“IP address”). This information is collected solely for the purpose of providing functionality and support for our internal operations and optimizing our users’ game experience.

Bubba Games does not permit behaviorally-targeted advertising to children in the Apps or in the Platforms where we have actual knowledge that the user is under the age of 13.

If you believe that we may have unintentionally collected your child’s personal information without your prior consent, you may contact Bubba Games Privacy Officer:

By e-mail: trewlapp@gmail.com

INFORMATION COLLECTED BY BUBBA GAMES

There are two types of information that may be collected by Bubba Games. The first is called personal information which is information that can be used to identify a specific individual. As stated in the previous section, Bubba Games does not knowingly collect any personal information from children outside of the information required for the support of internal operations. Bubba Games may collect personal information that parents, legal guardians or persons over 13 voluntarily provide on the Platforms. The second type of information is non-personal information which doesn’t directly identify an individual. Bubba Games may collect non-personal information about your use of the Platforms to help us improve our services or for other purposes as described in this Privacy Policy.

We may combine the non-personal and personal information you provide us through our Platforms. Information collected will vary depending upon the activity and may include your name, email address, phone number, mobile number, device type, operating system, home address, birth date, statistical and usage data (as further explained below), proof of identify (such as the Social Security, Social Identification Number or Social Insurance Number) of contest prize winners and, to the extent required to process any payment, your credit card information. In addition, we may collect demographic information such as gender, zip code or postal code and other data that you may provide in surveys or online profiles, for instance. We may combine demographic information with personal information.

European Economic Area (EEA) Only:

Per requirements under the EU’s General Data Protection Regulation (GDPR), we log your consent state for compliance purposes. This information is stored on servers hosted in the EU 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 our consent logging database if you do not consent to personalized advertising.

Please note that this data is collected automatically by third parties (controllers or processors under GDPR) due to your use of our products if you accept this Privacy Policy:

Data about your game progress;

Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);

Data about your device, such as device name and operating system, browser type and language;

General location data;

Precise geo-location data (GPS, with your consent);

Data about your use of our application or the game, such as gameplay data and your interactions with other players (if applicable).

Our software products include features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available below. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices. Some of our apps contain third-party advertising. We may occasionally promote other products of our own within our apps. We may occasionally cross-promote the products of other affiliated developers that offer similar products and share similar values as expressed on their own published privacy policies.

Google AdMob https://policies.google.com/privacy

Google’s safety center https://safety.google/

Privacy Notice for Google Accounts managed with Family Link, for children under the age of 13 (or the applicable age in your country) ('Privacy Notice') https://families.google.com/familylink/privacy/child-policy/

Google Payments Privacy Notice https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en

Unity and Unity Analytics https://unity3d.com/ru/legal/gdpr and https://unity3d.com/ru/legal/privacy-policy

Unity Ads https://unity3d.com/ru/legal/privacy-policy

Firebase Analytics https://firebase.google.com/support/privacy

AppLovin https://www.applovin.com/privacy/

ChartBoost https://answers.chartboost.com/en-us/articles/200780269

Vungle http://vungle.com/privacy/

StartApp https://www.startapp.com/policy/services-website-privacy/

Kidoz https://kidoz.net/website-and-kidoz-sdk-privacy-policy/

AppBrain https://www.appbrain.com/info/help/privacy/index.html

SuperAwesome https://www.superawesome.com/awesomeads-privacy-policy

InMobi Ads http://www.inmobi.com/page/opt-out/

My.com https://target.my.com/privacy/

Mobfox https://www.mobfox.com/privacy-policy/

Facebook Ads https://www.facebook.com/settings?tab=ads

AdColony https://www.adcolony.com/privacy-policy/

ironSource https://www.ironsrc.com/privacy-policy/

PURPOSES FOR WHICH WE USE THE INFORMATION COLLECTED

Bubba Games may use the personal information you provide us for the purposes of (1) administering contests and awarding prizes which are only directed to parents and adult users, (2) warranty registration and/or providing customer support or responding to technical service requests, (3) providing online services for parents and users over 13, (4) registration for games or special game-specific event participation for parents and users over 13, (5) registration for membership and participation on our Site, (6) processing your order(s) of products or subscriptions from us online;(7) enabling your use of our software or online services and access to certain areas of our Site, features or programs; (8) beta-testing; (9) newsletter sign-up or (10) improving our products and services. You are not required to provide personal information to us to obtain access to any of our Platforms; however, the collection, use and disclosure of your personal information is required for registration to access certain areas or features of our Platforms and, if you do not provide the required information, you will not have access to these areas or features.

Statistical and Usage Data: When you use our Apps on your device, we may retrieve information about your hardware system and how your game is played, including your IP address or device ID. We may also collect information about your computer, hardware, software, platform, media, connection, information about online activity such as feature usage, game play statistics and scores, user rankings, click paths, and in-app purchases. We use this information to enable you to play our game over the Internet. We also use this information to better understand the behavior and preferences of our customers, so that we can improve our products and services.

Other Uses: We may also use your information for other legitimate business purposes. Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill the purposes for which it was collected and our legitimate business objectives or as permitted or required by law.

Use of "Cookies": Our Site may use cookies to enhance your experience while using them. Cookies are pieces of information that some websites transfer to the computer that is browsing that website and are used for record-keeping purposes at many websites. Use of cookies makes Web-surfing easier by performing certain functions such as saving language preferences and maintaining your sessions while you are on our Site. The cookies used on our Sites contain generic information used for page navigation. If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, some areas of our Site may not function properly. We also use cookies related to the use of Google Analytics on our Sites. Google Analytics uses first-party cookies to report on visitor interactions. These cookies are used to collect information about how visitors use our Sites. We use the information to compile reports and to help us improve the Site. You can opt out of tracking by Google Analytics by visiting: http://tools.google.com/dlpage/gaoptout?hl=en-GB. In any event, we do not link information collected through cookies with any personally identifiable information.

Internet Protocol Address: We collect an IP address from every visitor to our Platforms. An IP address is a number that is automatically assigned to your computer or device when you use the Internet. We use IP addresses to help diagnose problems with our servers, administer our Platforms, analyze trends, track users' movement on our Platforms, gather broad demographic information for aggregate use in order for us to improve the Platforms, and deliver customized, personalized content. We do not link IP addresses with any personally identifiable information.

In-Game Advertising: Our Platforms may incorporate dynamic advertisement serving technology offered by our Ad Provider ( Adwords), which enables advertising to be temporarily uploaded into the game and replaced while you play. The data collected for this purpose may include IP address or players’ user name, downloaded or purchased Apps, in game location, length of time an advertisement was visible, size of the advertisements, and angle of view. The Apps you are using may be assigned an ID number, which is stored on your device, and used by our Ad Provider to calculate the number of unique and repeat views of dynamic in-game advertising. The ID number is not associated with any personal data and for children-directed Apps is not used for behavioral advertising purposes. None of the information collected and used for advertising purposes is used to personally identify you. The servers used by the Ad Provider may be located outside your country of residence. This ad serving technology is integrated into the Apps; if you do not want to use this technology, do not play the Apps while connected to the Internet.

In accordance with the General Data Protection Regulation (GDPR), Bubba Games 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.

HOW WE SHARE OR DISCLOSE INFORMATION

Bubba Games may share your information with third parties for the limited purposes described below.

Third Parties: You may register for other services from our Platforms which are offered by third parties. If you opt in to any of these third party services, we may collect additional information requested by this third party and pass this information, together with all other registration information (including personal information), to that third party. Use of your information by a third party will be governed by that third party’s terms of service and privacy policy. Participation in these other related services is optional and is not required to play or participate in any of our Platforms.

Partners: Bubba Games may also share non-personal information with our brand partners, which may include without limitation game session information, retention, purchases, gameplay events and user behavior. Bubba Games does not share any personal information with these partners.

Marketing: The personal information you provide will allow us to alert you to new products, features and enhancements; special offers; upgrade opportunities; and contests and events of interest. From time to time, we may also inform you on other companies and organizations that provide products or services that we believe may be of interest to you. We see this as a value-added service helping you to find useful products or services. We strive to limit use of the information you provide to those offers that we think you would appreciate receiving. You may opt out of this service by contacting us as set out in the opt-out provision below.

Legal Rights and Obligations: Finally, we may use and/or disclose your personal information to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage. When necessary, we may also disclose personal information to law enforcement, or to the appropriate civil authorities.

Bubba Gamesdoes not knowingly share or disclose personal information other than as set forth in this Privacy Policy.

OTHER IMPORTANT INFORMATION

Opt-Out Provision: Currently, Bubba Games does not share personal information with third parties for marketing purposes. In the event this was to happen, Bubba Games would obtain your consent prior to any such disclosure. If you do not want Bubba Games to send you postal mail about our products and services, you can opt out at any time and choose to have your name removed from our mailing list. Under the GDPR you have a right to have Bubba Games and our third party partners erase the personal information we have collected from you without undue delay. You can do so by contacting Clear Service’ Privacy Officer:

By email: trewlapp@gmail.com

By providing us your email, you accept to receive emails from Bubba Games with respect to our products and services. Additionally, by providing Bubba Games with your email on Facebook, such as through a sweepstakes or a newsletter sign-up, you accept to receive emails from Bubba Games with respect to our products and services. If you opt to receive such communications, you may opt out of this consent at any time by contacting us as described above or by using the unsubscribe mechanism included in the email communications you will receive. You may also modify your user settings to edit the email address related to your account or opt-out of receiving emails, at any time.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice, by contacting us as described above. Please note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services.

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 trewlapp@gmail.com

Safeguarding Your Personal Information: We will only collect and use personal information in accordance with this Privacy Policy to the extent deemed reasonably necessary to serve our legitimate business purposes, and we will maintain appropriate safeguards to ensure the security, integrity, accuracy and privacy of the information you have provided. In addition, we will take reasonable steps to assure that third parties to whom we transfer any personal information will provide sufficient protection of that information.

Under the GDPR you have a right to request a copy of the personal data Bubba Games and our third party partners have collected from you.

Business Transactions: We reserve the right to transfer any personal information we have about you in connection with the sale or transfer of all or a portion of our business or assets or rights relating thereto.

Third Party Sites: If you click on a link to a third party site, including on an advertisement, an Ad Provider link, or other third party service, you will leave the Bubba Games Platform you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as Bubba Games. We encourage you to review the privacy policies of these third party sites from whom you request services. If you visit a third party website that is linked to on a Bubba Games Platform, you should consult that site’s privacy policy before providing any personal information on that site.

Reviewing, Correcting and Deleting Your Information, Requesting Removal from Mailing Lists and Deactivating Your Account: If you wish to request access to your personal information or request that such information be corrected or deleted, or if you have any questions, comments, or concerns about this Privacy Policy or the information practices of Bubba Games, please contact Bubba Games Privacy Officer (contact information below). Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.

If we have unintentionally collected and stored any personal information from children under 13, parents can request access to review such information, have it deleted, or stop our further collection or use of such information. To make any of these requests (when applicable), please use the contact information below.

Consent: Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified at the time that we collect the information from you or as otherwise described in this Privacy Policy. In the case of children under 13, as applicable, we will obtain a parent or legal guardian’s verifiable consent prior to the collection of personal information from such users, unless the collection of such information falls within an exception that is permitted under COPPA.

For a better experience, while using our Service, I may require you to provide us with certain personally identifiable information. The information that I request will be retained on your device and is not collected by me in any way.

Privacy Notice for Google Accounts and profiles managed with Family Link for children under the age of 13 (or the applicable age in your country) (‘Privacy Notice’)

For your child to have their own Google Account or profile, we may need your permission to collect, use or disclose your child’s information as described in this Privacy Notice and the Google Privacy Policy. When you allow your child to use our services, you and your child are trusting us with your information. We understand that this is a big responsibility and we work hard to protect your information and put you in control. You can choose whether your child can manage their activity controls for things like Web & App Activity and YouTube History.

This Privacy Notice for Google Accounts and profiles managed with Family Link for children under 13 (or applicable age in your country) and the Google Privacy Policy explain Google’s privacy practices. To the extent that there are privacy practices specific to your child’s account or profile, such as with respect to limitations on personalised advertising, those differences are outlined in this Privacy Notice.

This Privacy Notice does not apply to the practices of any third-party (non-Google) apps, actions or websites that your child may use. You should review the applicable terms and policies for third-party apps, actions and sites to determine their appropriateness for your child, including their data collection and use practices.

Information that we collect

Once you grant permission for your child to have a Google Account or profile, their account or profile will generally be treated like your own with respect to the information that we collect. For example, we collect:

Information that you and your child create or provide us with.

As part of the account or profile creation process, we may ask for personal information like first name and surname, email address and date of birth. We collect the information provided by you or your child, such as your online contact details, which are necessary for us to contact you to request consent. We also collect the information that your child creates, uploads or receives from others when using their account or profile, such as when your child saves a picture in Google Photos or creates a document in Google Drive.

Information that we get from your child’s use of our services.

We automatically collect and store certain information about the services that your child uses and how your child uses them, such as when your child enters a query in Google Search, talks to Google Assistant, or watches a video on YouTube Kids. This information includes:

• Your child’s apps, browsers and devices
  We collect information about the apps, browsers and devices that your child uses to access Google services, including unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including operator name and phone number, and application version number. We also collect information about the interaction of your child’s apps, browsers and devices with our services, including IP address, crash reports, system activity and the date, time and referrer URL of your child’s request. For example, we collect this information when a Google service on your child’s device contacts our servers, like when they install an app from the Play Store.

• Your child’s activity
  We collect information about your child’s activity in our services, which we use to do things like recommend apps that they might like on Google Play. You can choose whether your child can manage their activity controls. Your child’s activity information that we collect may include things like search terms, videos that they watch, voice and audio information when they use audio features, people with whom they communicate or share content, and Chrome browsing history that they’ve synced with their Google Account. If your child uses our services to make and receive calls or send and receive messages, for example by using Google Hangouts or Duo, we may collect telephony log information. Your child can visit their Google Account to find and manage activity information that’s saved in their account or profile, and you can also help manage their activity information by signing in to your child’s Google Account or accessing their profile in Family Link.

• Your child’s location information
  We collect information about your child’s location when they use our services. Your child’s location can be determined by using GPS, IP address and sensor data from their device and information about things near their device, such as Wi-Fi access points, mobile towers and Bluetooth-enabled devices. The types of location data that we collect depends in part on your settings and your child’s devices.

• Your child’s voice and audio information
  We may collect your child’s voice and audio information. For example, if your child uses audio activation commands (e.g. 'Hey Google' or touching the microphone icon), a recording of the following speech/audio, plus a few seconds before, may be stored to their account from any of your child’s signed-in devices, when the Web & App Activity setting is enabled.

We use various types of technology to collect and store your child’s information, including cookies, pixel tags, local storage, such as browser web storage or application data caches, databases and server logs. We do not require your child to provide more personal information than is reasonably necessary to use the Google products and services available for these accounts or profiles.

How we use information that we collect

Google’s Privacy Policy explains in greater detail how we may use the data that Google collects in association with your child’s Google Account or profile. In general, we use your child’s information: to provide, maintain and improve our services; to develop new services; to customise our services for your child; to measure performance and understand how our services are used; to communicate directly with your child in relation to our services; and to help to improve the safety and reliability of our services.

We use different types of technology to process your child’s information for these purposes. We use automated systems that analyse your child’s content to provide them with things like customised search results and other features tailored to how they use our services. And we analyse your child’s content to help us detect abuse such as spam, malware and illegal content. We also use algorithms to recognise patterns in data. When we detect spam, malware, illegal content and other forms of abuse on our systems in violation of our policies, we may disable their account or profile or take other appropriate action. In certain circumstances, we may also report the violation to the appropriate authorities.

We may use your child’s information to provide recommendations, personalised content and customised search results. For example, depending on your child’s settings, Google Play may use information, such as the apps that your child has installed, to suggest new apps that they might like.

In addition, we may combine the information that we collect among our services and across your child’s devices for the purposes described above. Depending on your child’s account or profile settings, their activity on other sites and apps may be associated with their personal information in order to improve Google’s services.

Google will not serve personalised ads to your child, which means that ads will not be based on information from your child’s account or profile. Instead, ads may be based on information such as the content of the website or app that your child is viewing, the current search query or general location (such as city or county). When browsing the web or using non-Google apps, your child may encounter ads served by other (non-Google) ad providers, including ads personalised by third parties.

Information that your child can share

Your child may be able to share information, including photos, videos, audio and location, publicly and with others, when signed in with their Google Account or profile. When your child shares information publicly, it may be accessible through search engines such as Google Search.

Information that Google shares

Information that we collect may be shared outside Google in limited circumstances. We do not share personal information with companies, organisations and individuals outside Google except in the following cases:

With consent

We will share personal information outside Google with consent (as applicable).

With your family group

Your child’s information, including their name, photo, email address and Play purchases, may be shared with members of your family group on Google.

For external processing

We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with this Privacy Notice, the Google Privacy Policy, and any other appropriate confidentiality and security measures.

For legal reasons

We will share personal information with companies, organisations or individuals outside Google if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• meet any applicable law, regulation, legal process or enforceable governmental request;

• enforce applicable Terms of Service, including investigation of potential violations;

• detect, prevent or otherwise address fraud, security or technical issues; or

• protect against harm to the rights, property or safety of Google, our users or the public as required or permitted by law.

We may also share non-personally identifiable information (such as trends about the general use of our services) publicly and with our partners – including publishers, advertisers, developers or rights holders. For example, we share information publicly to show trends about the general use of our services. We also allow specific partners to collect information from browsers or devices for advertising and measurement purposes using their own cookies or similar technology.

Access to your child’s personal information

If your child has a Google Account, you can access, update, remove, export and restrict the processing of your child’s information by signing into their Google Account. If you do not remember your child’s password, you can reset it through the Family Link app or Family Link settings on the web. Once signed in, you can use the various controls described in the Google Privacy Policy, such as Google activity controls, to help to manage your child’s privacy settings and information.

If your child has a profile, you can access, update, remove, export, and restrict the processing of your child’s information through the Family Link app or Family Link settings on the web.

Your child will have the ability to delete their past activity in 'My activity', and by default grant app permissions (including things like device location, microphone or contacts) to third parties. You can also use Family Link to edit or modify your child’s Google Account or profile information, review app activity and app permissions, and manage your child’s ability to grant certain permissions to apps or third -party services to access your child’s information.

If at any time you wish to stop further collection or use of your child's information, you can delete your child’s Google Account or profile by clicking ‘Delete account’ or ‘Delete profile’ on your child’s Account or profile info page in the Family Link app or Family Link settings on the web. Your child’s account or profile information will be permanently deleted within a reasonable period of time.

The app does use third party services that may collect information used to identify you.

Kids Games:

• AdMob (Kid Safe Ads) - Privacy Policy | Opt Out

General Games:

• AdMob - Privacy Policy | Opt Out

• UnityAds - Privacy Policy

Link to privacy policy of third party service providers used by the app

• Google Play Services

• Google Firebase

• AdMob

CONTACT INFORMATION

If you have any questions or suggestions about my Privacy Policy, do not hesitate to contact me trewlapp@gmail.com