Last Updated: July 2022
This Policy answers the following questions:
Please read this document to learn why all the data is used and how it is treated prior to deciding whether you will give consent to the processing of the data relating to you. This document has been created in an attempt at full transparency. In case anything remains unclear, please contact us with your questions and concerns at the email address provided at the end of this document.
If any changes are made to this Policy, you will be informed accordingly. If needed, you will also be informed through an additional consent and consent renewal will be required.
1. Personal Data
1. 1. What personal data we collect?
Important Face Data Info
We do not collect, share, store, or process Face Data from our users.
a) Automatically collected data:
a) 1. Age – if you are a minor or not;
a) 2. Log information – info about your use of our app, the features you use, the type of device your use;
a) 3. Device information – the operating system of your device (device type), your mobile device identifiers (device ID, advertising ID), resolution, version of the application, language, time zone, as well as IP address;
a) 4. Consumption information – information about your activity within the Services, such as achievements within the Services, completed levels and actions taken within the Services, in-app purchases data (payment identification number, the type and amount of a product, its price in your local currency, date and time of the purchase), subscriptions, advertising that you click on;
b) Information we ask access for:
Contacts – we never store your contacts remotely, nor give them to third parties. We never use your contacts for any purposes outside the app. Your contacts remain on your device at all times. We do not store this data anywhere, nor do we upload this data to any servers,
1. 2. Why do we collect personal data?
All the aforementioned data collecting is done in accordance with the legal bases as described in the following paragraphs:
This data is used to identify if you are a child or an adult, and to determine the legal requirements for data protection. This is necessary for compliance purposes with Article 6(1)(c) of the GDPR.
1. 2. 2. Log, device, usage, and consumption
This information is processed in order:
- to provide and deliver the services requested by you, and to provide related information as agreed with you;
- to maintain and provide the app experience;
- to improve app content and features and personalize it as well;
- to monitor trends and activities related to the app, to analyze the trends, usage, and activities;
- to provide reasonable contextual advertisements in the app to children (as this term is construed under GDPR in the EU, COPPA in the US, and the relevant applicable legislation in other jurisdictions),
- alternatively, to provide all other users (except children) who have consent to share their advertising IDs with our ad network partners (specified in more detail under Information Sharing) in order to serve them with personalized ads in our apps (behavioral advertising).
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
Processing of Age for the afore-mentioned purposes is relevant as we take a legitimate interest in providing relevant content and advertisements to all our users as well as improving our services in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more under Information Sharing).
1. 3. How we store the data?
Your information will be stored as long as needed to provide our services for the purposes described in this document. Your personal data will be deleted or anonymized when it is no longer required for the fulfillment of the purposes described in this document, and no later than three (3) years after you’ve stopped interacting with our app.
1. 4. How is the data protected?
Protection against unauthorized access to all data, passwords, or device is important, and we take reasonable precautions to protect this data and secure all systems.
We retain all Personal Data for as long as you use the Services and 24 months after you stop using the Services. If you do not use the Services for 24 continuous months, we erase your Personal Data from our database, as well as request the same erasure from any third party, to whom your Personal Data may have been transferred. We may erase your Personal Data earlier if we do not need to process such data anymore.
If it is legally required that we retain your Personal Data for a longer period for whatever purpose as stated in the applicable law, we will retain your Personal Data for the period determined by the law. We will immediately erase your Personal Data after the such period expires or if the legal duty to retain such Personal Data is repealed.
We may retain your Personal Data longer only in case such Personal Data have been duly anonymized. After anonymization, the data are not considered Personal Data, as the end user (the data subject) is no longer identifiable.
Please, take into account that erasure of Personal Data is irretrievable. After your Personal Data have been erased, you will not be able to exercise the right to access, the right to erasure, the right to rectification, or the right to data portability.
Your information is disclosed to the following categories of recipients with legal bases in 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR:
Third parties – if we are required to share your personal data by applicable law, rule, regulation, or a legal process in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
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 the company or others;
Advertising network companies in order to serve contextual advertisements (the data include your IP address, Device ID, and advertising ID). If you have given consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within our app.
- Ad Mob -https://policies.google.com/privacy?hl=en
- Unity Ads -https://unity3d.com/legal/privacy-policy
- Facebook Ads -https://www.facebook.com/about/privacy/
- Adcolony -https://www.adcolony.com/privacy-policy/
- Chartboost -https://answers.chartboost.com/hc/en-us/articles/200780269
- AppLovin -https://www.applovin.com/privacy/
- IronSource -https://www.ironsrc.com/privacy-policy/
We may transfer your Personal Data to a third party in the following cases:
- if we need so to protect our legal rights, our end users, business parties, or other interested parties;
- if we need so to enforce our agreements with you;
- if we need so to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.
Our apps have social sharing features from Facebook and Google.
With social sharing features and other integrated tools within our apps, you can share actions you take in our app with other media. To do this, you must be over the minimum limit age prescribed by the legislation in the individual jurisdictions.
Using social sharing features and other integrated tools means sharing information with your friends or the public, depending on the settings established by you with the entity that provides the social sharing feature.
Your Rights Regarding Your Personal Data
If you are an EU citizen and fall within the scope of a data subject, you are entitled to the following rights, under the applicable data protection regulation:
- The right of access. You have the right to access your Personal Data, which we process;
- The right to erasure (deletion). You have the right to ask us to completely delete your Personal Data;
- The right to object. You have the right to object to the processing of your Personal Data for the purpose of direct marketing;
- right to restriction of the processing. Please, be informed that this right may be exercised only in a situation set forth in Article 18 of General Data Protection Regulation 2016/679;
- The right to data portability. You have the right to ask us to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller.
Advertising in the Services
The advertisements in our Services are shown with the help of third-party advertising partners. We integrate their technologies into the Services, which are then used by our partners to select the advertisements that meet your interests in the best way.
If you do not want to receive targeted advertisements, please, adjust the settings of your device as instructed below.
How to adjust privacy settings in your devices:
- iOS operating system: enable Limit Ad Tracking on iOS by opening “Settings,” then tapping on “Privacy,” then “Advertising”, and sliding the Limit Ad Tracking switch to “On”.
- Android operating system: opt out of Ads Personalization on Android by opening “Settings”, then tap “Google”, then “Ads”, then enable the switch next to “Opt out of Ads Personalization”.
We offer Services that include subscriptions. If you want to subscribe to our Services, this means that you’ll have to do this with the help of the in-app payment system provided by the Platform (either Google Play managed by Google or AppStore managed by Apple) and integrated into the Services. The in-app payment system is managed by the Platform administration or its authorized partner. Under no circumstances do we collect or process any information related to your payment instruments, such as bank card number, its validity term, or your name as written on it.
Push notifications or alerts are sent to your device to provide information about the app, service updates, promotional communication, or other related messages. We send push notifications only if you have agreed to that. You can deactivate push messaging by changing notification settings on your devices.
We are responsible for deciding how and why we collect and use your personal data. If you want to contact us, you can find our contact details in the section below.
For any questions and concerns, please send us an email at this address: firstname.lastname@example.org