This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. The Services are also governed by the Terms of Service.
This Privacy Notice applies to personal information that we collect through our games, mobile applications and other products ("Games"), and websites we control,(collectively “Services”).
The personal information we may collect about you through the Services falls into the following general categories:1.1. Information that you provide voluntarily
Certain parts of our Services may ask you to provide personal information voluntarily. For example, we may ask for certain information in order to register an account with us, to begin playing Games, to subscribe to marketing communications from us, and/or to submit enquiries to us, such as:
- Your name, email address or other contact details
- Any information you submit to our customer service team in the Game or via email
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be explained to you when we ask you to provide your personal information.1.2 Information 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:
- Your Service communications (e.g. in-game chats and messages with other players)
- 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 preferences or just game preferences, which friends you connect with, the means by which you were referred to our Services)
- Your IP address and device identifiers such as your Advertising ID, Device ID numbers (for more see here "Advertising IDs and Device IDs")
- Your device type and the operating system that you use
- General geographic location (e.g. country or city location) based on your IP address
- GPS location, with your consent
“Advertising ID” means the Apple Identifier for Advertisers (“IDFA”) on Apple, and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that advertisers use for interest-based advertising. They are consistent across all apps and thus allow cross-app tracking. On Apple, you can opt out by choosing the “limit ad tracking” option in the privacy settings. On Google Android, you can opt out by choosing the “Opt out of interest based ads.” Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
“Device identifier / information” means device type, device model, device manufacturer, device operating system and language, or other technical data like screen size, processor, or a combination of this data, available from a device for a developer to check the device’s compatibility with a particular application.
Some of this information may be collected using cookies and/or similar technologies (such as " software development kits, or “SDKs”).1.3 Information we obtain from third party sources
(a) Information from social media platforms. You may choose to connect to our Services via your social media account. The exact information we receive from you will depend on your social media privacy settings, but it will typically include your basic public profile information, such as:
Your friends playing the same Game
Typical uses include updating game progress on multiple devices you may own so that you can continue your progress using multiple devices. In addition, we may show your Facebook friends in the Game and show your public Facebook profile name and picture in Game leaderboards and in your Game profile.
(b) 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 or when, prior to installation, you click on an advertisement for the Game (see "Third Parties" section below for further detail).
(c) 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 directing you to one of our Services (such as an ad for one of our Games in another publishers’ game), we will be provided with information about which ad network and advertising campaign the install originated from (See also "Advertising" below).1.4 No special categories of information
We do not request or intend to collect any "special categories of information" such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. Please, be cautious when sharing this information about yourself (or others) in our forums.
We use your personal information for the following purposes:2.1 To provide and operate our Services:
- To create user accounts/profiles to enable you to play our Games
- To provide you with the correct versions of our games and/or applications (e.g. knowing which language to make our games available to you in)
- To enable you to communicate with other users (including via chat rooms or private messages) and leaderboards local to you
- To send you service-related communications including confirmations, technical notices, updates, security alerts, and support/administrative messages2.2 To improve our Services and keep them secure:
- To respond to your customer support requests (e.g. if you write to us with a complaint)
- To receive error messages about any issues you/your device encounters with our Services to enable us to fix bugs and interoperability issues
- To detect and prevent illegal activities (e.g. hacking or cheating)
- To track game installs (for purposes of measuring the effectiveness of marketing campaigns).
- To conduct optional user feedback surveys
- To understand you, your preferences and user traffic to enhance your experience and enjoyment using our Game
- To conduct research2.3 To personalize our Services:
-To remember you next time you visit one of our Services
- Communicate with you about promotions, rewards, upcoming events, and other news about products and services we offer2.4 For promotional activities (including marketing and advertising)
- To provide you with in-game offers and rewards based on your in-game behaviors
- To serve you with relevant targeted advertisements (necessary to fund our Services)
- To make you offers to purchase in-game items on discount based on your in-game activity and purchase history.
- To send you marketing communications and/or newsletters about rewards and promotions if you have subscribed to them2.5 Other
- To comply with our legal obligations
- To exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person
- To prevent and/or detect fraud or fraudulent behavior
The Services may use “cookies” and other technologies such as pixel tags, local shared objects, hardware-based device identifiers, flash cookies, operating system-based identifiers, clear GIFs and web beacons.
Cookies: A “cookie” is a small file your browsers stores when told to do so by a website. Typically, websites place a number of different cookies on an end-user’s device. Some are “First-party” cookies,’ i.e. from the website itself, and others are “Third-party” cookies, meaning they belong to advertising and analytics entities or social networks. Cookies are personal information. However, our cookies do not include any other personal information and are typically used to quickly identify your device and to “remember” your device during subsequent visits for purposes of functionality, preferences, and website performance. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where (i) we need the personal information to perform a contract with you, (ii) the processing is in our legitimate interests and not superseded by your rights, or (iii) we have your consent to do so.
(a) Under our terms of service, “performance of contract” as a legal basis for processing your information refers to when we make the Game and Services available to you, provide customer support, integrate Games with technology and distribution platforms such as Apple iOS and Google Android, and inform you of service-related changes and Game progress.
(b) We process your personal data on the basis of our legitimate interests for example when we provide you the Game and Game events, serve interest based advertisements to you (both in-game and on third-party properties), carry out marketing, keep our games secure, for engineering purposes, analyzing the users’ behavior across our Games, moderating chat discussion.
(c) We have a “legal obligation” to process your personal data when complying with a legal obligation, such as the preventing a crime or fraud or maintaining tax records.
(d) If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). If you have questions about, or require, further information concerning the legal basis for collecting and using your personal information, please contact us.
We may share your personal information with the following types of recipients:
(a) With companies in our business group, third-party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help enhance the security of our Services), or parties that otherwise process personal information for the purposes described in this Privacy Notice or communicated to you when we collect your personal information.
(b) With any competent law enforcement body, regulatory authority, government agency, court of law or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person
(c) With a potential or actual buyer (and its agents and advisers) in connection with any proposed or actual purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information solely for the purposes disclosed in this Privacy Notice
(d) With any other person, with your consent for such disclosure.
We use appropriate technical and organizational measures designed to protect the personal information that we collect about you and process. The measures we adopt are designed to provide a level of security appropriate for the degree of risk involved with processing your personal information. Specific measures include encrypting your personal information in transit and at rest.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, to provide you with a Service you have requested, or to comply with applicable legal, tax or accounting requirements. For example, we periodically de-identify unused Game accounts and regularly review and de-identify unnecessary personal information.
When we have no ongoing legitimate business need to process your personal information, we will either delete or de-identify it, or, if this is not possible _ for example, because your personal information has been stored on a backup server _ then we will securely store your personal information and isolate it from any further processing until deletion is possible.
You have the following data protection rights:
(b) To object to the processing of your personal information (which is processed on the grounds of legitimate interests), ask us to restrict processing of your personal information or request portability of your personal information. Again, you may do so by opting out of personalized offers based on in-game behavior, or by contacting us.
(c) To opt out of marketing communications we send you, at any time by contacting us .
(d) If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted pursuant to lawful processing grounds other than consent.
(e) You have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
When we collect personal information we do not know the age of our players. If we discover we has inadvertently gathered personal information from a minor under 13 years of age, we will take reasonable measures to promptly delete such personal information from our records.
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, in accordance with the significance of the changes we make.