Effective Date: 31 January, 2020
This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
Information we collect
Automatic collection of information
When you open the Mobile Application, our servers automatically record information that your device sends. This data may include:
- Technical information from your device, e.g. your device's IP address and location, device name and version, operating system type and version, device screen resolution, language preferences, etc.
- Information you search for in our Mobile Application, access times and dates, and other statistics.
- Advertiser identifiers, such as Apple’s Identifier for Advertisers (IDFA) and Google’s Advertising ID.
Information collected automatically is only used to identify potential cases of abuse and establish statistical information regarding Mobile Application traffic and usage. This statistical information is not otherwise aggregated in any way that would identify any particular user of the system.
Collection of personal information
You can access the Mobile Application without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. However, if you wish to use some of the Mobile Application's features, you will be asked to provide access to the gallery or/and other features on your mobile device.
You can choose not to provide us with your personal information, but then you may not be able to take advantage of some of the Mobile Application's features. Users who are uncertain about what information is mandatory are welcome to contact us.
Data we collect from our partners
- Demographic data (e.g. to determine the approximate location of your IP address).
- Data to fight fraud (e.g. refund abuse in games or click fraud in advertising).
- Data from platforms the games run on (e.g. to verify payment).
- Data for advertising and analytics purposes, for us to be able to provide you with a better service.
Why we collect your data
In order to make our Mobile Application available to you, or to meet a legal obligation, we need to collect and use certain personal information. If you do not provide the information we request, we may not be able to provide you with the requested products or services. We collect some of the information directly from you via our Mobile Application. However, we may also collect personal information about you from other sources. Any information we collect from you may be used to:
- Improve user experience and make the service more suitable for our users.
- Run and operate our Mobile Application and services.
- Show personalized advertisements.
In all the above cases, we may analyze, profile, and segment all collected data.
How we store personal information
We will retain and use your personal information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your personal information after you update or delete it, but not in any manner that would identify you personally. Once the retention period expires, personal information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
How we process personal information
The ways we process your personal information depend on how you interact with our Mobile Application, where you are located in the world, and if one of the following applies: (i) you have given your consent for one or more specific purposes (this, however, does not apply whenever the processing of personal information is subject to the California Consumer Privacy Act or European data protection law); (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases above. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and, in particular, whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Information transfer and storage
Our Mobile Application is designed for global use. Therefore, your data can be transferred to or stored in any country. Since data protection laws may vary from country to country, we and our partners make every effort to protect your personal information as described in this Policy by providing the required safeguards, which include the standard provisions of data protection regulations approved by the EU Commission and obtaining Privacy Shield certification to ensure secure transfer of data to the USA.
You may exercise certain rights regarding your information processed by us. In particular: (i) You have the right to withdraw consent where you have previously given your consent to the processing of your information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Mobile Application features to you. We will advise you if this is the case at the time you withdraw your consent. (ii) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. (iii) You have the right to learn if the information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing. (iv) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. (v) You have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it. (vi) You have the right, under certain circumstances, to obtain the erasure of your personal information from us. (vii) You have the right to receive your information in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
Any requests to exercise User rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible.
We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Mobile Application. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide personal information through our Mobile Application without their permission.
If you have reason to believe that a child under the age of 13 has provided us with personal information through our Mobile Application, please contact us. You must also be at least 16 years of age to consent to the processing of your personal information in your country (in some countries, we may allow your parent or guardian to do so on your behalf).
Links to other mobile applications
Our Mobile Application contains links to other mobile applications that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other mobile applications or third parties. We encourage you to be aware when you leave our Mobile Application and to read the privacy statements of each and every mobile application that may collect personal information.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to prevent any unauthorized access, use, modification, and disclosure of personal information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your personal information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Mobile Application cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
In the event we become aware that the security of the Mobile Application has been compromised or Users’ personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if such notice is otherwise required by law. When we do, we will post a notice in the Mobile Application.
We will disclose any information we collect, use, or receive if required or permitted by law, e.g. to comply with a subpoena, or similar legal process, and 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.
Changes and amendments
If you would like to learn more about this Policy or wish to contact us concerning any matter relating to individual rights and your personal information, you may email us at firstname.lastname@example.org
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