Privacy Policy
This policy describes how GMI (greatminds innovations) and, its other group companies (collectively described as “GMI”, “we”, “us” or “our”) and its third party marketing and advertising partners collect, use, process and share information about you.
This Privacy Policy applies to all of our games, whether played on mobile devices, PCs or on other platforms such as Facebook. It also applies to our activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our games, websites, marketing and advertising activities and other services collectively as our "Services".
By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy. , including consenting to GMI's and our advertising partners’ use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. Those sections also explain how you can withhold or withdraw your consent to the use of your data for targeted advertising purposes. If you have any other concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services.
This Privacy Policy was last updated on 21.05.2020.
Our games
By downloading, accessing and/or playing our games or using our other Services, you consent to the collection of information about you by us. Most of this data comes directly from you or your device, such as device information, country and region, and game play information. We use this data to provide our games and Services to you, including for the purposes of optimization, preventing fraud, customizing in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising purposes.
Most of the information that we collect about you comes directly from you when you play our games, or interact with our websites, advertising or other Services. Broadly the information we collect about you relates to the type of device you are using, how you play our games (such as levels attempted and purchases made) and may include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.
In more detail, depending on which of our Services you interact with we may collect and process the following types of information:
details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our website(s), what device you use to access our games and services or details regarding profile visits, as further set out here;
information that you provide us with when you fill in forms, answer questions or complete surveys when using any of our Services, when you create an account with us or if you invite your friends to use our games and Services;
the content of messages sent using our chat and messaging systems;
your interactions with us on our social media channels;
information we collect via cookies and other similar technologies, as explained further below;
information we collect about you from our other group companies or other third party companies who have obtained your consent or have another legal right to share such information with us (including publishing partners, platforms, advertising platforms and partners and data aggregators who have obtained). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use this information as described in this Privacy Policy and subject to any limitations in the privacy policy of the company that collected the information from you.
If you choose not to connect to your social media account, the information that we collect when you play our games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including:
the type of device(s) you are using to play our games or access our Services, identifiers such as IP address, device identifiers, ad identifiers, and the country or region that you are playing in; and
how you play our games and interact with our websites or other Services (such as which of our games you are playing, your progress through the games, session time and duration, number of attempts at each level and purchases made).
In some instances, when you make purchases on or through our website(s), we may collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by GMI. We do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful.
When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play) we do not collect or store any payment information from you.
We, our suppliers and group companies, may use this information:
to enable us to provide our games and other Services to you, to ensure that any purchases you make are verified on our servers and activated in the games, and to provide you with player support if you need it;
to enable us to optimize our games for you and for the device that you are using, as well as to deliver customized in game events, offers and promotions;
For the other purposes as set out in this Privacy Policy, including for Marketing and Advertising purposes; and
We may also share your information with third party publishers who develop and provide games and other Services to you on our behalf.
We also analyse and use the information that we collect on an anonymied or aggregated basis for product development, to analyse the performance of our games, to troubleshoot and to improve and optimize the games to ensure the best player experience for our players as a whole.
A more detailed description of some of the ways that we use your information is set out below and in the other sections of this Privacy Policy.
Analytics and Research
We use analytics tools, which may include third party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content.
Social and Community
We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.
Cheating, crime and fraud prevention
We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police.
Legal uses
We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.
Playing Socially
You can choose to connect our Services to your account with a third party network (such as Facebook or google).If you do this, you will be able to use your account to log in on multiple devices and synchronize progress across those devices. Where available, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress), or access other functionality we make available in our games and other Services, such as inviting friends to play, asking other players for lives and 1-2-1 messaging.
Information we receive from Facebook
If you log in to your Facebook account details, we will receive some of your Facebook account information. If you choose to play our games online on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your game Profile. Exactly what information we receive will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information.
Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see you and your progression in our games, you can prevent this by disconnecting from Facebook from within our games and updating your app permissions from within your Facebook settings.
We would recommend that you read Facebook’s Privacy Policy (https://www.facebook.com/full_data_use_policy) and review your privacy settings from time to time to make sure that you understand fully how your Facebook data is shared.
Information we receive from Google
If you log in to your Profile using your Google account details, we will receive some of your Google account information. Exactly what information we receive will depend on your settings in your Google account, but typically we will receive your basic public profile information such as your name, email address and profile picture.
You can revoke future access to your information at any time by following the steps at https://support.google.com/accounts/answer/112802?hl=en.
We would recommend that you read Google’s Privacy Policy (https://www.google.com/policies/privacy/) and review your privacy settings from time to time to make sure that you understand fully how your Google data is shared.
Marketing
Unless you opt out as explained below, we and our third party partners use information collected about you to send you marketing communications about other games and related Services based on your interests. For example, we may send emails, serve ads within our Services or place ads on third party websites, apps and Internet-connected devices.
What information do we use for marketing?
We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as:
ad identifiers and other non-personal information collected from your device.
the games you play and information about how you interact with our games and Services;
your age, country or region, and gender; and
other information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
This Privacy Policy does not apply to the collection of your information by our partners. We recommend that you review our partners’ privacy policies for more information. A list of our partners and their privacy policies can be found here.
Advertising
Our games may include advertising for third party products and services. By accepting this Privacy Policy and downloading or continuing to play our games or use our Services, and unless you opt out of interest-based advertising as explained in this section, you consent to us and our advertising partners collecting and using information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games.
We use information that we hold about you to better target ads for third party goods and services to people that might be most interested in them. These ads may be shown to you within our games or Services.
“Survey Serving Technology
Some of our apps may use Pollfish SDK. Pollfish is an on-line survey platform, through which, anyone may conduct surveys. Pollfish collaborates with Developers of applications for smartphones in order to have access to users of such applications and address survey questionnaires to them. When a user connects to this app, a specific set of user’s device data (including Advertising ID which will may be processed by Pollfish only in strict compliance with google play policies- and/or other device data) and response meta-data is automatically sent to Pollfish servers, in order for Pollfish to discern whether the user is eligible for a survey. For a full list of data received by Pollfish through this app, please read carefully Pollfish respondent terms located at Pollfish. These data will be associated with your answers to the questionnaires whenever Pollfish sents such questionnaires to eligible users. By downloading the application you accept this privacy policy document and you hereby give your consent for the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by using the Pollfish “opt out section” available on Pollfish website . We once more invite you to check the respondent’s terms of use, if you wish to have more detailed view of the way Pollfish works.
APPLE, GOOGLE AND AMAZON ARE NOT A SPONSOR NOR ARE INVOLVED IN ANY WAY IN THIS CONTEST/DRAW. NO APPLE PRODUCTS ARE BEING USED AS PRIZES.”
What information is used for advertising?
We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our games that might be of interest to you. This includes information such as:
ad identifiers and other information collected from your device. For more information;
the games you play and information about how you interact with our games and Services;
your age, country and region, and gender; and
other demographic and interests based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
Opting-out of interest-based advertising
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your android or iOS device and selecting 'limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android).
Please note that if you opt out of interest based advertising, you will still be able to play our games and you may still see advertising in our games but those ads will not be targeted using information that we hold about you. However, they may still be delivered based on contextual criteria such as the game that ad is to be displayed in, or the region in which your device is located.
Your rights
You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.
Those rights include:
Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 2 months of receipt of your request and verification of your identity.
Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know by emailing us and we will correct it as soon as we can.
Data deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please email us. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.
Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below).
Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
There are other ways in which you can control the personal information that we collect about you. For instance, you could disconnect your Facebook or other social network account from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone. Finally, you could limit or prevent the use of cookies in your web browsers. More information on all of these options is provided elsewhere in this Privacy Policy.
Age Limits
We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13 please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn of that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.
General
Our Privacy Policy contains further details about:
Sharing
In addition to the other disclosures described in this Privacy Policy, we will also share your information:
where we have your consent to do so (including as set out in this Privacy Policy);
as reasonably necessary in order to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfill the Services or to communicate with you);
where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment processors);
where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
as we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of GMI, our users, or others; and
if there is a sale of the assets of GMI or corporate restructuring, or as a result of a change of control of GMI or one of its group companies, or in preparation of any of these events. Any third party to which GMI transfers of sells GMI's assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.
We may also share your information with our service providers if necessary to enable them to provide services to us.
Security
GMI takes appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.
Retention
We will keep your information for as long as your account is active or we consider necessary for the purposes described in our Privacy Policy. We will also retain and use your information for as long as is required in order to comply with our legal obligations.
International Transfer
We may transfer your information to affiliated entities or third parties to jurisdictions outside the EEA. Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU model clauses) to allow the transfer of your information across borders outside of the EEA.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us.
Contact us
If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several way of contacting us:
1. via email to greatmindsoftwares; or