I. INTRODUCTION
(“we,” “us” or “our”) takes your privacy seriously. This Privacy policy (“Privacy policy”) explains our data protection policy and describes the types of information we may process when you install and/or use software application for mobile devices (the “App”, “our App”) and explains how we and some of the companies we cooperate while processing that information.
This Privacy Policy explains what personal data is collected when you use our mobile applications (the “App”), websites and related services (together with the App, the “Service” or “Services”), how such personal data will be used, shared.
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) delete the App from your devices.
When we refer to personal data (or personal information) we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data.
It is a natural person who can be identified directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social status.
Our Privacy policy applies to all users, and others who access the App (“Users”).
For the purposes of the GDPR, we are the data controller, unless otherwise stated.
PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED, CAREFULLY. WHEN YOU USE THE APP YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.
II. Information that you submit
INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
Information provided by you when using the Games (“Basic Information”)
We will collect the following information from you when you play our Games:
- a unique pseudonymous identifier for you (User ID);
- your user preferences; and
- anonymous core information milestones related to your gameplay, such as the completion of certain activities during your gameplay.
Information used for the purposes of serving advertisements (“Advertising Data”)
Through our third-party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:
- the make, model and operating system of your device;
- properties of your device, such as screen size and orientation, audio volume and battery;
- the mobile network operator linked to your device;
- the Games played;
- the country, time zone and locale settings on your device (i.e. country and preferred language);
- network connection type and speed;
- IP Address;
- MAC address;
- internet browser used to access the Games; and
- the advertiser ID, which is an identifier unique to you if you use an Android device, but which doesn’t reveal your name.
Information collected for the purposes of providing analytics (“Analytics”)
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
- your mobile device’s unique device ID (“Device ID”);
- your User ID (which is generated by us and allocated to you when you first play our games);
- your device operating system & version;
- your device brand and model;
- game play attempts, progression and results;
- session game time start, end and duration;
- purchase transaction types;
- the country of your device;
- the time, date and install source of your first download (e.g. from a clicked advertisement);
- advertisements viewed and clicked; and
- identification of crashes and defects.
INFORMATION WE DO NOT COLLECT AND SHARE ABOUT YOU
Your Photos: Your photos may be uploaded to our servers for processing, but we do not store them longer than necessary for processing. The photos are deleted immediately after processing, and we do not collect or share them with any third parties.
Facial Data: We do not retain any facial data from you.
Email and Personal Data: We do not collect your email when you contact us, and we do not collect any other personal data from you across all our products.
Information about you collected from third parties (“Third-Party Login Information”)
When you access the Games via a third-party social media provider such as Facebook, Twitter or Game Center, we may collect and store personal and non-personal information which is available on that third-party social media provider, such as your Facebook or Twitter name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook cookies within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.
III. WHY WE COLLECT INFORMATION ABOUT YOU
To provide our Games to you
We will use information about you (including Basic Information, Third-Party Login Information and Analytics) for delivering our Games to you under the terms of use agreed between us. The processing of information in this way is necessary for us to record your progress and current status within a Game, and to ensure the Games deliver the features promised and function properly, so that you have the best experience when playing any one of our Games.
To help us improve the Online Services and fix any problems
We may process non identifiable Analytics so that we can analyze and improve our Games and Online Services.
This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when playing any of our Game(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Games and Online Services and iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.
We use third-party providers Adjust (user attribution and analytics), Game Analytics and Google Firebase (for analytics). Adjust, Game Analytics and Google Firebase may collect analytics on our behalf and in accordance with our instructions, and their applicable privacy notices.
If you would like to find out more about the way Adjust, Game Analytics and Google Firebase collects and processes this information this is likely to be set out in their privacy policies and/or terms and conditions. Please refer to https://firebase.google.com/support/privacy/
For advertising purposes
We may process Advertising Data to show you advertisements for third-party services.
The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements.
We will not process your information for the purposes of marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already. After you have given your consent, you may with ONNECT at any time.
We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third-party advertising networks:
Admob https://support.google.com/admob/answer/6128543
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
IV. SHARING OF YOUR INFORMATION
We will share your information with third parties only in the ways that are described in this Privacy policy. We adhere to the U.S. Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment.
We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the App. We do not control or influence these third parties’ tracking technologies or how they may be used.
We may also share certain information such as cookie data with third-party advertising partners. This information allows third-party ad networks, inter alia, to deliver targeted advertisements that they believe will be of most interest to you.
We may engage the following third parties in order to provide us with necessary infrastructure for delivery and improvement of our services.
Our App may contain links to third-party websites / services or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them.
We may disclose your personal information if it is needed for objective reasons, due to the public interest or in other unforeseen circumstances:
as required by law;
when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
V. INTERNATIONAL DATA TRANSFERS
We work in the cross-border area and provide our App to our Users around the world.
We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction.
This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of personal data as your country does.
We try to make sure that the recipient of any personal data provides a proper protection of the personal data received, in accordance with the current legislation on the protection of such information. By using the App, you agree that we may transfer your personal data to any third country, a territory or one or more specified sectors within that third country, or to the international organization.
VI. HOW LONG WE USE YOUR PERSONAL DATA
We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.
However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.
VII. EXERCISING YOUR RIGHTS
For the personal data we store and access you are entitled to address us regarding the following issues:
Data Access and Portability. You can request copies of your personal information held by us.
Change or Correct Data. Where you cannot update data by yourself through your account, you have the right to ask us to correct change, update or rectify your data.
Data Retention and Deletion. We generally retain data for as long as your account is in existence or as it is needed to provide services of the App. However, specific retention times can vary based on the context of the processing we perform and on our legal obligations. You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also delete your account at any time. We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, or where we have a legitimate interest in doing so (e.g. to prevent fraud and abuse and maintain and enhance security).
Restriction of Processing. Under certain circumstances, you may have the right to limit the ways in which we use your personal information.
Please bear in mind that we ensure the above mentioned rights only with respect to the information that you submit.
When your personal information that is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in Section IV of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options.
Please mind when you opt out of certain interest based advertising, you may still continue to receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.
VIII. SECURITY
The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.
Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.
If you have any questions about the security of our App, you can contact us at through email or contact form displayed below.
IX. CHILDREN’S PRIVACY
Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under age 18 may provide any personal information to the App. If you are under 18, do not use or provide any information on this App or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.
X. CHANGES TO THE PRIVACY POLICY
This Privacy policy will be regularly updated.
Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.