ZMMY games and other applications (“ZMMY GAMES“, “us”, “our” or “we“) are highly serious in protecting the privacy rights of our users (“users” or “you“). This Privacy Policy (the “Policy”) describes the ways we collect, store, use, and manage the information including personal information, that you provide or we collect, we believe that your privacy is really important to us or any ZMMY game or application provided on a mobile platform (collectively, the “Service”). Please note that the scope of this Policy is limited to information collected or received by ZMMY through your use of the service. ZMMY GAMES is not responsible for the actions of third party people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites or placements by those sites does not constitute our sponsorship of, or affiliation with, those people or companies. This Policy describes the personally identifiable information and other data that we will collect from you through the apps and games we provide, and how we will use and when we might display such data to third parties. Your installation and/or use of these Apps and/or submission of information to us establish your consent to this Privacy Policy and the processing of your information (personal and non-personal) as described in this policy. Please don’t use the Services if you do not agree to this Privacy Policy.
If you have any questions or comments about this Privacy Policy, please contact us at zmmygames@gmail.com
Please read this Privacy Policy carefully as it contains important information about the following:
⦁ What information we may collect about you;
⦁ How we will use information we collect about you;
⦁ Whether we will disclose your details to anyone else; and
⦁ Your choices and rights regarding the personal information you have provided to us.
INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
a) Information provided by you when using the Games or Apps
(“Basic Information”)
We may collect the following information from you when you play our Games or use our Apps:
⦁ Your mobile device’s unique device ID (Device ID);
⦁ Photos/Media/Files
⦁ Read the contents of your USB storage
⦁ Modify or delete the contents of your USB storage
⦁ Storage
⦁ Read the contents of your USB storage
⦁ Modify or delete the contents of your USB storage
⦁ Wi-Fi connection information
⦁ Full network access
⦁ View network connections
⦁ Your user preferences; and
⦁ Core information related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores or the completion of certain activities during your gameplay (for example, completing a tutorial, passing a level, making a purchase or viewing a video ad).
b) 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 Apple or Android device, but which doesn’t reveal your name.
c) 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 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 make and model;
⦁ Game play attempts, progression and results;
⦁ Session game time start, end and duration;
⦁ Purchase transaction types and spend you have made using virtual items in the Games;
⦁ 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.
d) Information about you collected from third parties
(“Third Party Log In Information”)
When you access the Games or Apps via a third party social media provider such as Facebook, twitter or any other we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook 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 within the Games or Apps. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.
Privacy Policies of Linked Third Party Services and Advertisers
Our websites and apps may contain advertisements from third parties, which are companies other than ZMMY GAMES that may link to their own websites, online services or mobile applications. We are not responsible for the privacy practices or the content of these third parties, and the collection, use, and disclosure of your information will be subject to the privacy policies of those third parties. If you have any questions about how these third parties use your information, you should review their policies and contact them directly.
Please see the links below to learn more about the data practices of the third-party advertising partners that we use or may use:
WHY WE COLLECT INFORMATION ABOUT YOU
a) To provide our Games or Apps to you
We will use information about you (including Basic Information, Third Party Log in Information, Analytics and User Content) for delivering our Games or Apps 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.
b) To help us improve the Online Services and fix any problems
We may process information about you (including Basic Information, User Content and 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.
c) To acquire new users and engage current users
We may process information (including some Advertising Data and Analytics) to encourage engagement from our less active users and to notify them with new virtual items or other promotions on offer.
We may also process this information to pursue our legitimate interests of acquiring new users for our Games.
We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you.
d) To improve the monetization of the Games via in-app purchases
We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via in-app purchases. This may include the implementation of dynamic pricing models, so that in-app purchases are priced according to relevant factors, such as geography and gameplay progression so that we can offer temporary promotional discounts.
e) For advertising purposes
We may process Advertising Data to show you advertisements for third party services; including advertising that may reward you with benefits during your use of the Games.
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 aggregate this information so that it does not personally identify you or permit you to be treated individually.
We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games.
We will not pass or process your information for the purposes of marketing by third parties unless you give your consent should we ask for it. After you have given your consent, you may withdraw it 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.
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.
f) To prevent fraud and illegal activity
We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, and does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.
Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.
We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.
We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).
DATA SHARING
We will share your information with third parties only in the ways that are described in this Privacy Policy
Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, any third party to which we sell or transfer our assets to will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy Policy.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of ZMMY GAMES, our customers, or others.
Digital Content Stores: Where the Games are downloaded through Google Play, iTunes and/or Amazon Appstore, we may disclose your personal information to Google, Apple and/or Amazon respectively for the purposes of facilitating any in-Game payments made through these platforms.
AUTOMATED DECISION MAKING
We may use automated decision making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy
We may process your personal information via automated decision making methods in order to identify users who are suspected of cheating in the Games. Our automated decision making methods are designed to detect cheating by looking out for (i) excessive currency stores against actual completed gameplay; and (ii) excessive content against actual purchases made and completed gameplay.
If users are determined to be or suspected of cheating the following actions may be taken and which will be unknown to the user:
⦁ An increase in the number of advertisements displayed within the Games; and
⦁ An increase in the frequency of suspected cheats playing against other suspected cheats.
We may block users from the Games and/or the Online Services who are determined to be cheating following an automated decision process. In this scenario the user will be notified of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Games and/or the Online Services.
CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to be part of a lookalike campaign, receive notifications from us or be served with targeted advertisements you can opt-out by changing your advertising and notification settings on your device directly.
You can withdraw your consent to targeted advertising by changing your advertising settings on your device at any time.
YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let us know by sending an email to zmmygames@gmail.com.
a) Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
b) Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
⦁ You consented to our processing the personal data, and have withdrawn that consent;
⦁ We no longer need to process that personal data for the reason it was collected;
⦁ We are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of ZMMY GAMES or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
⦁ The personal data was unlawfully processed;
⦁ You need the personal data to be deleted in order to comply with legal obligations;
⦁ The personal data is processed in relation to the offer of a service to a child.
c) Obtain a machine readable copy of your personal data, which you can use with another service provider
⦁ If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
⦁ If you request, we will supply you with the relevant personal data in digital format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
d) Make a complaint to a Supervisory Authority
⦁ If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the email.
⦁ If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
Additional information for users in Europe
This section of the policy applies to the users that are located in the European Economic Area (EEA),
Switzerland or United Kingdom (UK). Zmmy Games processes your personal data in accordance with
European laws and regulations, such as the General Data Protection Regulation (GDPR) and UK
General Data Protection Regulation (UK GDPR).
(a) Controller's details
For the purposes of the GDPR and UK GDPR, Zmmy Games is the controller of your personal data, and we
can be contacted using the details provided.
In certain circumstances, we process personal data as a processor on behalf of our customer. Zmmy Games
Terms of Use set out the circumstances where Zmmy Games processes personal data as a processor. In
these cases, it is the Zmmy Games customer that is responsible for the processing of your personal data and
processing will be governed by the terms of the Data Processing Addendum it has entered with the
customer. If you have questions or concerns about how your personal data is handled by one of our
customers, you should contact the relevant customer that is using our Service and refer to their separate
privacy policies.
(b) Legal bases for processing
If you are located in the EEA, Switzerland or UK, we need a lawful basis to collect, use and disclose your
personal data as a controller. Our lawful basis will depend on the information concerned and the context
in which it is processed.
Generally, Zmmy Games will collect and use your information as follows:
Contractual necessity: We need it to provide the Service to you and fulfil our obligations to you under our
Terms of Use. For example, this includes creating and maintaining your account, resolving issues you
may experience with the Service, obtaining payment for our Services and providing you with access to
your designs.
Legitimate interests: It is necessary for our legitimate interests for example, providing a useful and
customized Service, sending you relevant marketing messages, displaying advertising and tracking its
effectiveness, using information we collect about you (like your spending, platform usage, occupation and
employer) so that we can make more informed predictions, decisions and offers for our users, helping
users connect with team members and their employer's and enhancing our Service via research and
development, data analytics, data labelling, machine learning and predictive analytics relating to your
usage data. We do not rely on this lawful basis where our legitimate interests are overridden by your
rights and interests.
Consent: You consent to us, and our third party partners, using your information in a certain way – for
example, to hear about new features or offers, and for machine learning and predictive analysis relating
to your User Content.
Legal obligations: It is necessary for compliance with our legal obligations – for example, to disclose your
information in response to law enforcement requests and to retain your information for our record
keeping purposes.
If you consented to our use of your information, you can withdraw that consent at any time. Depending
on the situation you can either withdraw your consent by emailing zmmygames@gmail.com.
Where we use your information for our legitimate interest, you have the right to object to that use by
contacting zmmygames@gmail.com. However, if you do, it may diminish the quality of the Service you receive or
prevent you from using the Service.
(c) Cross-border transfers of information
By signing up, you understand and agree that Zmmy Games will receive and process your personal data. We
may transfer your personal data to other countries where our affiliates and service providers are located.
Please note that some of these countries may have data protection laws that are different from your
country (and, in some cases, may not be as protective). For users in the EEA, Switzerland or UK, where
we transfer your information to a third-party service provider that is not located in Europe, and is not in a
country that benefits from an adequacy decision by the European Commission, UK or Swiss authorities,
we will require those third party providers to enter into an agreement that provides appropriate
safeguards for your information, including by using the EU Model Clauses and the UK International Data
Transfer Addendum.
Summary: If you are accessing our Service from Europe, Zmmy Games is the controller of your personal
data. In some cases, though, we may only be processing your information on behalf of a Team as a
processor. We only process your data if we have a lawful basis. We may transfer your information
outside of Europe subject to appropriate safeguards.
Additional information for users in the United States
This section of the policy applies to Zmmy Games users that are located in the United States. In certain U.S.
states, Zmmy GamesTech users have additional rights afforded to them under applicable state privacy laws,
including the California Consumer Privacy Act as amended by the California Privacy Rights Act, the
Virginia Consumer Data Protection Act, the Colorado Privacy Act, and the Connecticut Data Privacy Act.
DATA RETENTION
We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.
Google Checkout:
If you choose to use Google Checkout to finalize and pay for your order, you will provide your credit card number directly to Google Checkout. Google’s Privacy Policy will apply to the information you provide to the Google Checkout web site.
CHILDREN
We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at zmmygames@gmail.com.
SECURITY
We will take all reasonable technical and organizational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as ZMMY GAMES management or employees whose main role requires system access).
Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
Additional Information related to privacy policy:
This Privacy Policy explains how your personal data is collected and processed. We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent. We encourage you to review the Privacy Policy whenever you access the App or Game to stay informed about how we process your personal data and how you can protect your privacy.
HOW WE COLLECT YOUR PERSONAL DATA
We acquire, utilize, and process your personal data through various means. In every instance, we are committed to safeguarding your personal data.
In the sections outlined below, we detail how we collect your personal data and how we handle that data.
PERSONAL DATA
When you access or use our applications or games, we may collect general information about you, including:
· Log Information: IP Address, access time, device type, your name, email address and cover photos (if you have connected to Facebook or other social sites or platforms), and your general (city/country) location (in some cases both precise and approximate location (based on your Internet Protocol (“IP”) address)
· Device Information: device manufacturer, device type, hardware type, device operating system, device time zone, and device language.
· Device Identification Number: the online identification number of the device you use to access the Application, including IDFA, Google Ads ID, Google Device ID, Game Center ID, and Google Play account ID.
· Usage Information: game progress, scores, achievements, and your interactions with other players.
· Commercial Information: Purchase and usage history and preferences, the receipt of virtual goods in-game.
Automatically Collected Data
As part of providing our services, we may automatically collect certain data from your device. This data is primarily used to improve the functionality of our app and to provide a more personalized experience. The types of data that may be automatically collected include, but are not limited to, the following:
Server Logs:
Our servers may automatically collect and store information about your interactions with the app. This can include:
Device Information: Type of device, operating system version, and unique device identifiers (such as IMEI or MAC address).
IP Address: The IP address of your device is recorded when connecting to our servers for communication purposes and to ensure the security of our services.
App Usage Data: Information about how you use our app, including the features accessed, interactions within the app, and timestamps for various actions. This data helps us analyze app performance and improve user experience.
HTTP Logs:
When you interact with our app, certain HTTP requests and responses may be logged for system maintenance, troubleshooting, and to monitor app performance. These logs may include:
Request Headers: Information related to the request your device sends to the server, including the device’s browser type, language settings, and cookies.
Response Status Codes: Information about the response sent back to your device, including success or error status codes.
URLs Accessed: The specific URLs or resources you request from our servers, which help us understand which features are most popular or need improvement.
Data Transmitted via Google API (Actions on Google):
If our app integrates with the Actions on Google API, we may collect data from interactions with Google Assistant, Google Home, or other devices and services that use Google APIs. This data could include:
User Queries and Commands: The voice or text inputs you provide when using Google Assistant to interact with our app. This data is necessary for processing your requests, such as searching, setting reminders, or retrieving specific information through the app.
Interaction Metadata: Information about the context of your interactions with Google Assistant, including timestamps, device type, and any associated Google account data (if logged in).
Activity Data: Actions performed via the Google Assistant, such as whether a particular action was completed successfully or if an error occurred during processing.
How We Use Automatically Collected Data
The data collected through these methods is primarily used for the following purposes:
Improving Service Performance: To troubleshoot and optimize our app, ensuring that it runs smoothly and efficiently.
Analyzing User Behavior: To better understand how users interact with our app and identify areas for improvement or new features.
Security and Fraud Prevention: To detect and prevent fraudulent activity, abuse, or misuse of the app.
Personalized User Experience: To customize and tailor content or functionality based on your preferences and activity within the app.
Data Retention
The collected data is stored securely and retained only as long as necessary for the purposes outlined above. If you choose to delete or uninstall the app, some logs or data related to interactions may be retained in accordance with legal, regulatory, or technical requirements.
Your Control Over Automatically Collected Data
You may have the option to limit or disable certain data collection practices through your device’s settings, such as disabling location access, turning off permissions for Google Assistant, or using privacy settings on your device. However, please note that disabling certain features may affect your experience with the app.
If you have any concerns or wish to exercise your rights regarding your data, please contact us at zmmygames@gmail.com
Permissions Required for App Functionality
Our apps may request certain permissions to provide a better user experience and to ensure the proper functionality of specific features. These permissions are necessary for the app to operate and enhance the features and services that we provide. Below is a list of the permissions that our applications may request:
Advertising ID: Used to serve personalized ads and analyze the effectiveness of advertisements.
Foreground Services: Allows the app to run tasks in the foreground, ensuring continued operation even when the app is not in active use.
Control Vibration: Enables the app to control the device's vibration function for certain alerts or notifications.
Google Play Billing Service: Used to enable in-app purchases and transactions within the app.
Network Access: Grants the app permission to access the internet for various features such as online services, updates, and data syncing.
View Network Connections: Allows the app to check the status of your network connections (Wi-Fi, mobile data, etc.).
Use of Play Install Referrer API: Helps us measure the source of app installations to track and analyze marketing campaigns.
View Wi-Fi Connections: Lets the app access information about your Wi-Fi connections for features like online connectivity.
Receive Data from the Internet: Allows the app to receive data from the internet to ensure up-to-date content and services.
Install Shortcuts: Grants the app permission to create shortcuts on your device's home screen.
Read/Write Shared Storage: Provides the app access to your shared storage for saving, modifying, or deleting files, including media and documents.
Camera (Take Pictures and Videos): Enables the app to access your device's camera to take pictures or record videos.
Microphone (Record Audio): Permits the app to record audio through your device's microphone.
Modify/Read SD Card Contents: Allows the app to access, modify, or delete the contents stored on your SD card or shared storage.
Change Audio Settings: Provides the app the ability to adjust your device's audio settings, such as volume levels.
Pair with Bluetooth Devices: Enables the app to connect and interact with Bluetooth-enabled devices.
Flashlight: Grants the app permission to control your device’s flashlight for features such as using the camera flash or flashlight functions.
Set Wallpaper: Allows the app to change the wallpaper on your device's home screen or lock screen.
Google Play License Check: Verifies the authenticity of the app through Google Play's licensing service.
Location (Precise and Approximate): The app may request access to your device's location for specific features, such as providing location-based services, displaying nearby places, or enabling GPS functionality. This may include both precise location (using GPS) and approximate location (using Wi-Fi or network-based methods).
These permissions are necessary for the functionality of our app and to provide a personalized and seamless experience. We are committed to safeguarding your privacy and ensuring that your personal information is handled responsibly. You can review and manage these permissions directly in your device’s settings.
If you have any questions or concerns about the permissions requested by our app, feel free to contact us at zmmygames@gmail.com
OTHER DATA SOURCES
If you log in to the application via a website or third-party platform such as Facebook, Apple Game Center, and Google Sign-In, we will access information about you from that website or platform, such as display name, profile information, and your friends' list, in accordance with the authorization procedures determined by the website or third-party platform, provided that you have agreed with that website or third-party platform.
You can learn more about how websites or third-party platforms process your personal data in the relevant privacy policies:
· Facebook: https://www.facebook.com/about/privacy/
· Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/
· Google Play Games: https://policies.google.com/privacy
If you log in to the application via a website or third-party platform, you declare and warrant that (i) your access to and use of those features related to the application will comply with the current terms and policies of that website or platform; and (ii) you have exceeded the minimum age limits set for that website or third-party platform according to the laws in the respective legal jurisdictions.
HOW WE USE INFORMATION
We use information about you for the following purposes based on the legal basis for each type of personal data as described below:
· Fulfill product orders and other requests, respond to your questions, and communicate with you
· Provide services, enhance and personalize your experience on the services
· Send you news, technical messages, updates, privacy warning and technical support
Our processing of your data for the purposes mentioned above is necessary to fulfill the contract you are a part of, support the operation of the Application, provide the products and services you request, and allow for the maintenance and updates of the Application. This is in accordance with Article 6(1)(b) of the GDPR, also known as the "balancing of interests" rule.
We may send you news and marketing communications based on your preferences and choices, including information about Scopely or third-party offerings that we think may interest you.
We aim to enhance and personalize your experience on the Services, while also maintaining your preferences and settings.
Additionally, we may review the use and performance of the Services, develop new products or services, and conduct analyses to improve our software, content, marketing, support, and overall Services.
Our processing for the above purposes is justified by our legitimate interest in providing advertisements and content that you are interested in as well as improving our services according to Article 6(1)(f) of the GDPR.
· Deliver personalized advertising and marketing and relevant promotional information to users who agree to share their Advertising IDs with our ad network partner
Information from other sources that are being processed”
· Fulfill product orders and other requests, respond to your questions, and communicate with you;
· Understand your preferences, interests and provide you better, personalized services;
· Deliver information and news about services, applications that you might be interested in;
Our action for the above purposes is justified by our legitimate interest in providing advertisements and content that you are interested in as well as improving our services according to Article 6(1)(f) of the GDPR.
DATA RETENTION
We'll keep your information for as long as necessary to provide you with the Services, fulfill our legal obligations, and/or exercise, defend or establish our rights. We may still retain some of your personal information in our files for a reasonable period of time to resolve disputes, enforce our terms and policies, administer our Services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Services
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service or we are legally obligated to retain this data for longer time periods.
SHARING OF INFORMATION
Subject to your legal rights, based on Article 6(1)(b), 6(1)(c) and 6(1)(f) GDPR, we may disclose the information we collect about you, and may enable you to share this information, with a variety of third parties in various ways, including:
· Social media platforms, see more in “Social sharing” Feature;
· Other third parties (e.g., for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, and other purposes with your permission);
· The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of zmmy games or others;
· Other users, such as when you participate in open communities or events, or information published on leaderboards.
When you agree with the information in Article 6(1)(1) GDPR, we will share your Device identifiers to advertising network companies. This will help to serve you personalized advertisements. We use or may user the following advertising network:
· Applovin Corporation: https://www.applovin.com/privacy/
· Facebook, Inc.: https://www.facebook.com/about/privacy/
· Google LLC: https://policies.google.com/privacy
· Google Admob: https://support.google.com/admob/
· Unity Technologies: https://unity3d.com/legal/privacy-policy
· Vungle, Inc.: https://vungle.com/privacy/
· Pangle: https://www.pangleglobal.com/privacy/partner
· Mintegral: https://www.mintegral.com/privacy
The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.
In connection with our processing, we use following data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers:
· Facebook Analytics (Facebook, Inc.) https://www.facebook.com/about/privacy/
· Firebase (Google LLC) https://firebase.google.com/support/privacy
PUSH NOTIFICATIONS
We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.
YOUR RIGHTS
We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:
· The purposes of the processing;
· The categories of personal data concerned;
· The recipients or categories of recipient to whom the personal data have been or will be disclosed;
· The envisaged period for which the personal data will be stored.
Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of- interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.
If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Under CCPA each California resident can request any business stop selling personal information to third parties.
You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.
You can request us to disclose what personal data we have collected on you in the past 12 months.
We can assure you that our Privacy Policy is a relevant document where you can find information about what personal data we have collected about you over the past 12 months and intend to collect, sources of your personal data and how we use your personal data.
You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access). You can make this request for free, twice per year.
When providing information under the right of access, we will provide you with the following information:
· The categories of personal data we are collecting about you,
· The categories of sources of the personal data,
· The purpose for collecting your personal data,
· The categories of any third parties with whom we share your personal data,
· The specific pieces of personal data collected about you.
You can request us to delete the personal data we have collected on you in the past 12 months.
We fully recognize your right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for a certain period of time. For instance, if we need to provide services to you, detect or resolve security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.
CHANGES TO THIS PRIVACY POLICY
We reserve the right, at our sole discretion, to change, modify or otherwise alter this Policy at any time. You must review this Policy on a regular basis to keep yourself apprised of any changes.
If you do not agree to any modifications to this Policy, your sole recourse is to immediately stop all use of all Applications, the Services and the Site. Your continued use of any Application,
The Services or the Site following the posting of any modifications to this Policy will constitute your acceptance of the revised Policy. Please note that none of our employees or agents has the Authority to vary any of our Policies.
CONTACT INFORMATION
All questions, comments or inquiries should be directed to ZMMY GAMES at zmmygames@gmail.com. We will endeavor to respond to any query or questions within business days.