Last updated: June 10, 2020
1. INFORMATION WE COLLECT FROM YOU
Most of the information that we collect about you comes directly from you when you visit our website, 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 enquiries to us, such as:
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:
Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile device 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 “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
A list of our current service providers and partners is available here .
(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. Kindly be cautious when sharing this information about yourself (or others) in our Services.
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, for complying with our legal obligations and for our legitimate interests (for example, when we use your personal information for evaluation of possible employment relations with you).
We use your information for the following 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 or Amazon.com account (payment service providers). You are requested to provide your payment details and personal information directly to such payment service providers. We are not involved in the collection and processing of such information: instead, we will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
3. HOW WE SHARE YOUR INFORMATION
We cannot provide all 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:
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.
The list of our current service providers and partners as well as more detailed information about processing is available here.
We reserve the right to disclose your information (including personally identifiable information) in response to 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 email@example.com
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 or at low cost and in order to do that we need to share 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 website and Games and – at the same time – keep our Games free for a wide player base.
As a European-based company, when you use our Games, we rely on our legitimate interest to show advertisements to you. The legal basis to show ads is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer.
Before sharing any information with our advertising partners for the purposes of personalized advertising , we always ask for your consent , given when you press accept at relevant button at loading of the Game. The purpose is to improve our Games and provide the player with more relevant ads. We allow our advertising partners to show personalized ads to you only if you have pressed ACCEPT in relevant pop-up window and so consented to the sharing of your personal information for the purposes of personalized advertising. Our advertising partners use different technologies for the purposes of personalized advertising that process your personal information in different ways, so please review their data processing practices before you ACCEPT to show you personalized ads at loading of the Game. The list of our current advertising partners with links to their privacy policies is available here .
The legal basis to show personalized ads is consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements.
You have an option to withdraw your consent to sharing your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the Game settings and clicking the Terms and Privacy button there then then unchecking the Personalized Ads Consent item. Changes might be taken into account at next application start only, according to the advertising partners. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.
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 the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here ) including:
4.3. View of Our ads on third-party services
We may also advertise the 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 (please refer to the Privacy Notices of our advertising partners listed here ) including:
4.4. WHO CAN SHOW PERSONALIZED ADS TO YOU?
Please see the list of advertising providers that are allowed to show personalized advertising and review their data processing practices, including the technologies they use for the purposes of personalized advertising here .
4.5. HOW CAN YOU TURN OFF PERSONALIZED ADS?
Besides specific instruments available to users via the Game you can use your device settings.
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.
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. THIRD-PARTY SOCIAL NETWORKS
5.1. Connecting to Third-Party Social Networks
Some of our Games use third-party services such as Google Play Games Service, Apple Game Center, Facebook (“Third Party Social Network/s”). Such Games enable you to log in to your Third-Party Social Network account to connect our App by using the “Log in” feature in our App. You may also share the content you create within the App on Third-Party Social Networks. These services are not activated automatically, but require explicit authorization by You. Please note, Third Party Social Networks are governed by their own privacy policies, terms and end-user agreements and we are not responsible for and have no control over, the sharing practices or policies of the third parties that operate those sites. For additional questions, contact us at firstname.lastname@example.org.
5.2. Information We May Receive When You Connect to Third-Party Social Networks
The information you allow us to access varies by App and is affected by the privacy settings you establish on those Third-Party Social Networks. You can control and find out more about these settings from the Third-Party Social Network in question. When you use the “Log in” feature, we may access and store some or all of the following information, as allowed by you, Third-Party Social Networks and your preferences: (i) your basic information from your public profile. By default, this includes certain information about you such as id, name, picture, gender, and your locale. If you have made more of your information public, more information will be available; (ii) login ID and/or player identifier string; (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the “Log in with” process. We may share your name and your game data (such as moves, Game progress and scores) with respect to the applicable App, with your friends who have also used the “Log in with” or “Connect to” feature in connection with such App or with your contacts in applicable Third-Party Social Media Network account.
The App may further ask you to allow us to post on such Third-Party Social Networks on your behalf (e.g. status updates). Please keep in mind that we will only do that if specifically allowed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the App on your device so that the App will be able to communicate with Third Party Social Network directly.
5.3. How You Share Your Information On Third-Party Social Networks
If you use Third-Party Social Networks to participate in game-related activities, such as leaderboards and multiplayer games, you share your information with other players and Third-Party Social Networks (for example, scores, rankings, and achievements).
6. INFORMATION WE COLLECT FROM OUR WEBSITE
6.1. In general
When you are using our website we may obtain your personal data, from you directly (for example, at the time of subscribing to any services offered on our website, including posting materials and etc.); and/or from your device or browser. Such personal data may include:
We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of our website.
7. CHILDREN’S PRIVACY
Our Service does not address anyone under the age of 13 (“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 13. 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 13 without verification of parental consent, we will take steps to remove that information from our servers.
Under our Terms of Service users of our games must be at least 13 years of age. Although the graphical content of the games may be suitable for younger audiences, there are multiple reasons for responsible developers to apply a minimum age of 13. Some of these reasons are in-app purchases and privacy.
Please note: When you download our games from e.g. Google Play or Apple App Store you will find published age recommendations in the Apps description. However, these age or maturity classifications refer only to the content suitability (similar to movie ratings G, PG or PG-13 in the U.S., but related to gameplay, animations, etc.) according to the respective rating body responsible for such ratings. As these ratings are done independently by a third party without our contribution, they are not necessarily in line with our Terms of Service.
For more info on how these categories are defined, visit these support websites for Apple and Google.
8. YOUR RIGHTS
You have certain rights in connection with your personal information and how we handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by following the instructions below or sending us relevant requests to email@example.com
Your rights include:
10. LEGAL BASES
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA data protection law.
The legal bases that we rely upon are the following:
In any case, We will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
12. INTERNATIONAL TRANSFER
The information is processed at the Pacolabs’s operating offices and in any other places where the parties involved in the processing are located.
Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
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 “Your Rights” Section.
Once the retention period expires, Personal Data 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 expiration of the retention period.
14. Information for Californian consumers
This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).
14.1. Categories of personal information collected, disclosed or sold
In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section 2 titled “How we use your information” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you according to the CCPA: identifiers, commercial information, internet information and geolocation data.
We will not collect additional categories of personal information without notifying you.
14.2. How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use our services and Games.
For example, you directly provide your personal information when you submit requests via any forms on the services or Games. You also provide personal information indirectly when you navigate the services and Games, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of the Games and features thereof.
14.3. How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.
To find out more about the purposes of processing, please refer to the relevant section of this document.
14.4. Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration ”.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, simply by following the instructions below.
Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document or by following appropriate link within the Game.
14.5. What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of the services or Games and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.
14.6. Your California privacy rights and how to exercise them
The right to know and to portability
You may submit once a year, free of charge, a verifiable request to disclose what personal information we collect about you. The easiest way to submit a request is to use the in-app support feature (“Contact Us”) in our Games (if possible). You may also submit your request via e-mail at firstname.lastname@example.org .
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so. However, we may deny your deletion request if retaining the information is necessary for us or our service providers under certain circumstances, which will be explained to you at the time of the denial, if any. Should you wish any information about you deleted, you may use the in-app support feature (“Contact Us”) in our games (if possible) or submit your request via e-mail email@example.com.
Right to opt-out
You have the right to opt-out of “sale” of your personal information, as defined by the CCPA. In certain circumstances we may share your information with our partners, who help us deliver advertisements in our games tailored to your interests. To learn what information we collect and how we share it with third parties for advertising purposes, please, visit the link .
Right to be free from discrimination
We may not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny your our Services; (ii) charge you different prices or rates for our Services; (iii) provide you a different level or quality of Services; (iv) suggest that you may receive a different price or rate for Services or a different level or quality of Services.
You may exercise your CCPA rights by designating an authorized agent. If you would like to designate an authorized agent to make a request on your behalf, please, be sure that the agent can (i) demonstrate you have provided written permission for the agent to submit a request on your behalf and (ii) provide proof of his or her own identity. We reserve the right to require further reasonable information to verify the request. If the agent does not satisfy these requirements, we may deny the request.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 1 request over a period of 12 months.
How and when we are expected to handle your request
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. Our disclosure(s) will cover the preceding 12 months period.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
16. CONTACT US