This Privacy Policy explains who we are, how we process (i.e. collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destruct) personal information about you, and how you can exercise your privacy rights. We, a developer and publisher of games and mobile game applications that are made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our games, mobile applications and other products (“Games”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein. 1. INFORMATION WE COLLECT FROM YOU Most of the information that we collect about you comes directly from you when you play our Games or interact with third-party ads in our Games or with our ads in other publisher’s Games. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our Games and may include information that you submit to us when you voluntarily contact us. We may also collect information from app store platforms and partners and other third parties such as information about your interests and in-app purchases (provided that we never receive your payment or credit card information). The information that we may collect about you through the Services broadly falls into the following categories: (a) Information that you provide voluntarily Certain parts of our Services may ask you to provide personal information voluntarily. For example, we will ask for certain information in order for you to submit inquiries to us, such as: your name, email address or other details, necessary to process your inquiries; any information you submit to our support team via email. The personal information that you are asked to provide and the reasons why you are asked to provide it, we will try to explain to you at the point we ask you to provide your personal information. (b) Information that we collect automatically When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as: Data and analytics about your use of our Services (e.g. in-game play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed, in-game references or just game preferences, the means by which you were referred to our Services) Your IP address and device identifiers such as your Advertising ID, Device ID numbers. Your device type and the operating system that you use Your Service communications (e.g. in-game emotion signals which you exchange with other players) Broad geographic location (e.g. country or city-level location) based on your IP address Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for the mobile devices that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt-out of it by choosing the “limit ad tracking” option in your privacy settings. On Google Android, you can opt-out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device. Device identifier/information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application. Some of this information may be collected through cookies as explained further under the heading Cookies below. (c) Information we obtain from third-party sources Third-party service providers. We may receive personal information about you from third-party sources. We may get your personal information for example when you installed our Game and prior to installing you have clicked an advertisement for the same Game. Advertising partners. From time to time, we may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement to direct you to one of our Services (such as an advert of one of our Games in other publisher’s game), we will be provided with information from which ad network and advertising campaign the install originated from (See below also “Advertising”). (d) No special categories of information We do not request or intend to collect any “special categories of information” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. 2. HOW WE USE YOUR INFORMATION 2.1. In General We use the information we collect about you/your device to deliver services and our Games to you and to operate our business. We use it also for improving our services and Games, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services and Games in our Games and also in other publisher’s apps and to display third-party advertisements to you. We use your information also for tracking and fraud prevention for advertising purposes and for complying with our legal obligations. We do not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, we do not sell your data. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please contact us to exercise your right to withdraw your consent on sharing your personal data with third parties. We use your information for the following purposes: Delivering and improving our services. We use your information for developing, delivering and improving our Games and other products, services, and content, tailoring our products and services, providing Game updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Games, and administering the Games. Displaying advertisements. We use your information for showing advertisements for our Games in other publisher’s apps and for displaying third-party advertisements in our Games. Please see more in the Advertising Section of this Privacy Policy. Cross-promotion. We use your information for cross-promoting our Games and services, meaning to promote one of our Games while you are playing a different Game of ours. Tracking and fraud prevention for advertising purposes. We use your information for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns. Analytics and research. We use your information for understanding and analyzing trends in connection with the usage of the Games, gathering demographic information about our user base, data about where the Game was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example, to track potential problems or trends with our Games and services, or to test our new game features and content. Security. We use your information for enhancing the safety and security of our Games, products, and services. Customer Support. We use your information for providing customer support to you and to respond to your inquiries. Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes. 2.2. In-App Purchases Our Games enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the app store via your App Store account, Google Play account. Any post-purchase processes are controlled by Apple, Google stores and are subject to specific terms such as Apple, Google stores. Please review the privacy policy and terms of service of your Apple, Google stores. You can always request a refund from the applicable link below: iOS: https://support.apple.com/en-us/HT204084 Google Play: https://support.google.com/googleplay/answer/7205930 To cancel your subscription please visit the applicable link below and follow the instructions: iOS: https://support.apple.com/en-us/HT202039 Google Play: https://support.google.com/googleplay/answer/7018481?hl=en&co=GENIE.Platform%3DAndroid 3. HOW WE SHARE YOUR INFORMATION We cannot provide all the services necessary for the successful operation of the Games by ourselves. We must, therefore, share collected information with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’ advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it. We may share such information to: Our analytics providers. We use third-party analytics such as Unity, Firebase, Thinkingdata for the purposes of delivering our services, conducting analysis, and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. We can aggregate the data for benchmarking feature. Our cloud service providers. We store information we collect from you on servers provided by our third-party cloud service providers such as iCloud, Google Cloud Platform; Our tracking and fraud prevention providers. For some of our Games, we use tracking and fraud prevention providers, such as Tenjin for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes. Such providers may use APIs, and SDKs in our Games to enable them to collect and analyze user and device-related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-app events. Third-party advertising partners. We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Games for free or at a low cost. Advertising partner’s third-party tracking provider. We allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. They may use their own third-party tracking providers. Other third-party service providers. For our Games, we use Unity Software to develop such Games. For the data processing by Unity please see Unity’s privacy policy available at https://unity3d.com/legal/privacy-policy. For some Games, we partner with third-party development studios to develop such Games. Such third-party development studios do not have access to your personal information, they can only access aggregated data that they cannot trace back to you. We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Games. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices. We reserve the right to disclose your information (including personally identifiable information) in response to the law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party. For any additional questions about third-party information collection, please refer to contact section. 4. ADVERTISING 4.1. In General We use advertising to fund our Services and to make our games available for free. We offer our Games for free and in order to do that we need to share the information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve our websites and Games and – at the same time – keep our Games free for a wide player base. 4.2. In-game advertising (i.e. when you view ads in Our Games) To enable us to show in-game ads, we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our games (it is controlled by ad networks), but we do blacklist certain categories of ads. Advertising IDs are used by ad networks for a number of purposes including: limit the number of times you see the same ad; ensure they are dealing with humans with real devices and not ‘automated’ bots; serve you with advertisements likely to be relevant to you based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in Our Games. The ad network or ad exchange acts as an intermediary between the other game companies and Us. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID; keep track of what games you have used to market you similar kinds of games. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at the city level). 4.3. View of Our ads on third-party services We also advertise Games in other apps by asking ad networks to serve them to audiences that will be interested in them (determined using Advertising IDs). The Advertising IDs are used by the ad networks for a number of purposes including: measuring ad effectiveness (looking at aggregated views, clicks and installs they generate through their advertising in other publishers’ games); informing players, that have not been playing for a while, about new content in the Game. We give a list of these users in the form of Advertising IDs to an ad network. Ad network then shows these users ads about the new content; not showing ads on a game that a player is already playing. We can send a list of active players in the form of Advertising IDs to an ad network. Ad network then excludes these players from seeing the ad; marketing games to a group of potential players. 4.4. HOW CAN YOU TURN OFF PERSONALIZED ADS? Besides specific instruments available to EEA-based users via the Game you can use your device settings. iOS Open the “Settings” application of iOS and select the “Privacy” menu item and then the “Advertising” sub-item. If you activate the “Limit ad tracking” option, we can only take limited measures such as identifying unique users or combating fraud. In the same menu, you can always delete the IDFA (“Reset Ad-ID”), then a new ID is created which is not merged with the data collected earlier. Android Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalisation” to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID in the same menu at any time (“Reset advertising ID”), then a new ID will be created which will not be merged with the previously collected data. 5. 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. 6. COOKIES Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some options for our Service. Most web browsers allow you to control cookies through your browser settings. To find out more about cookies generally and how to manage or delete them, you can visit here. Find out how to manage cookies on popular browsers: - Google Chrome (here) - Microsoft Edge (here) - Mozilla Firefox (here) - Microsoft Internet Explorer (here) - Opera (here) - Apple Safari (here) To find information relating to other browsers, visit the browser developer's website. 7. CHILDREN’S PRIVACY Our Service does not address anyone under the age of 16 (“Children”). When we collect personal information, we do not know the age of our players. We do not knowingly collect personally identifiable information from children under 16. If you are a parent or guardian and you are aware that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 16 without verification of parental consent, we will take steps to remove that information from our servers. 8. YOUR RIGHTS We would like to make sure that you are fully aware of all of your data protection rights. As a data subject, you have a variety of rights regarding the use and control of your user data. In certain circumstances, you have the following data protection rights: - The right to access or delete the data we have on you. You have the right to access your personal data that we hold about you. If you request a copy of your personal data, we will provide you a copy in an electronic format after passing our verification process. However, if you choose to delete the data, some features that require such data may no longer be available. - The right to rectify. If you consider that personal data we hold about you is inaccurate or incomplete, you have the right to obtain rectification with your personal data without undue delay. - The right to object and restrict. You have the right to object to our processing of your personal data or request that we restrict the processing of your personal data. You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held). - The right to data portability. You have the right to be provided with a copy of the data we have on you in a structured, machine-readable and commonly used format. - The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal data. You can withdraw your consent previously granted to us for a specific purpose by deleting data, turning off device features, and requesting to withdraw consent, including the collection, use and/or disclosure of your personal data that we manage or control. If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of our products and Services. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent. - Right to control your privacy settings. You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal data via such privacy settings. For example, you can choose to turn on or turn off the permissions of “Location Access” or “Storage”; you can obtain detailed data regarding the device security status or change such status in “Privacy Settings” on your device. - Right to close your account. You can close your account by following the instructions in our Services or by contacting us for help. Please understand that for security reasons, your account cannot be closed unless you follow our instructions. We hereby kindly remind you that, if you wish to close your account, such closure may prevent you from using our Services, and such closure is irreversible. Once you close your account, we will delete or de-identify your relevant data. If you sign in to the accounts through a third-party account (e.g., via Facebook, Google ID), you need to apply for account closure from such third party. How to exercise my rights You can submit all your claims and questions with respect to such rights to [email protected]. Your requests will be answered as soon as possible and within thirty days at the latest. 9. GENERAL Your information privacy and security is important to us and we always pay special attention to ensure that we process your information lawfully. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. 10. LEGAL BASES In each case where we process your information, we do so lawfully in accordance with the legal bases. The legal bases that we rely upon are the following: Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Games (such as in-app chat feature, multiplayer feature, leaderboards, and other third-party social network features), to deliver content of the in-app purchase you make. Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Games free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes. Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for your consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys. Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance, is to maintain records for tax purposes. 11. SECURITY We have implemented appropriate technical and organizational measures to protect the confidentiality, security, and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable. 12. INTERNATIONAL TRANSFER For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may also transfer your personal data to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. In the circumstance that we transfer personal data outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws. 13. RETENTION We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than two (2) years after your interaction with all of our Games has ceased. When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data we will delete your data as described above in the “Your Rights” section. 14. CHANGES TO OUR PRIVACY POLICY We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. 15. Jurisdiction Specific Supplemental Terms According to the applicable laws of some jurisdictions from which you access or use the Services, we may supplement this Policy with jurisdiction specific terms. Such supplemental terms constitute an integral part of this Policy. In the event of a conflict between the provisions of the Supplemental Terms and the rest of this Policy, these Supplemental Terms shall prevail. (1) For California Residents: If you are a California resident, you are entitled to request notice of certain information about the user information that we may share with third parties for marketing purposes (e.g., the categories of user information shared, and contact information of applicable third parties), as well as request that we disclose to you what personal data we collect, use, disclose and sell about you, the right to opt out of the sale of your information, and the right to request deletion of personal data we collect or maintain about you. If you would like to exercise any of these rights, please email your request to us as provided above. You also have the right to not be treated in a discriminatory manner for having exercised your rights regarding your privacy rights under the California Consumer Privacy Act (CCPA). (2) For users in the European Union (EU), European Economic Area (EEA), and Switzerland: If you are a resident in the above countries, you may also have a right to complain to a data protection authority about our collection and use of your user information. For example, you can lodge a complaint with your local supervisory authority (EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC). 16. CONTACT US If you have questions or concerns about this Privacy Policy, please contact us via our privacy email: [email protected].