Last updated: May 23rd, 2018
WHAT PERSONAL INFORMATION WE COLLECT AND WHERE?
We collect the following categories of personal information about you through the Service:
Information that you provide voluntarily
Certain parts of our Service may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details 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. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Specifically, the information we collect directly from you may include information like (i) your name; (ii) your email address and other contact information; (iii) your user name or any other name you use to identify yourself in any Service; and (iv) other personal information required in order to help you with any queries or support matters you may need assistance with via our forums or customer support service.
Information that we collect automatically
When you use our Service, we may collect certain information automatically from your device. This information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, advertising identifiers, operating system, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how you use the Service and how your device has interacted with our Service, including the Games played and the pages of our Website accessed.
Collecting this information enables us to better understand the players of our Games and visitors who come to our Website, where they come from, and what content or features on our Games and Website is of interest to them. We use this information to serve interest-based advertising to you, for our internal analytics purposes, to prevent fraudulent behaviour in our Service and to improve the quality and relevance of our Service to our players and visitors.
Some of this information may be collected using cookies or similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
Information that we obtain from third party sources
We may receive personal information about you from third party sources, like sign-in and social networking services.
You can log in to our Games using sign-in services such as Apple Game Center or Google Play. We warmly recommend that you use these sign-in services. Otherwise it may be impossible for us to help you to transfer your game progression to your new device. If you choose to use these sign-in services, we receive and process your account ID number and user name of the sign-in service.
Our Games also include some social media interaction tools. If you choose to connect to Facebook through our Games, we receive and process (i) your name, (ii) your user ID number, (iii) your profile picture or its URL, and (iv) the list of your friends. Connecting to Facebook through our Games may allow you to interact with your friends relating to our Games.
WHY WE PROCESS YOUR PERSONAL INFORMATION AND ON WHAT LEGAL BASIS?
We collect and use your personal information for the following purposes. Our legal basis for collecting and using the personal information is also described below.
For the performance of the contract between us and you
For the performance of the contract we collect necessary personal information to
- create accounts and user profiles and allow players to play our Games and use our Service;
- verify and confirm payments;
- provide and deliver products and services you request; and
- send you related information, including confirmations and administrative messages.
To provide you with optimal Games and Service
To customize and provide you with optimal Games and Service we have a legitimate interest to collect and process necessary personal information to
- update and develop user profiles;
- operate our Games and Service;
- analyse, develop and improve Games, other Service and user experience;
- manage our relationship with you;
- identify and suggest connections with other users of our Games;
- respond to your comments and questions, resolve the problems and provide other kind of player support;
- analyse, profile and customize your use of the Games and Service;
- provide you offers in our Games and Service as well as in other web sites and services, or by email;
- send you related information, including technical notices, updates, security alerts, and support and administrative messages;
- enable you to communicate with other players; and
- link or combine information with other information we get from third parties, to help understand your preferences and provide you with better services.
Show you personalized advertisements
Unless you have opted out, to show you personalized advertisements (so called behavioural ads) in our Games and Service as well as in other web sites and services, or by email we have a legitimate interest to collect and use necessary personal information to
- track the content you access when you use our Games or your device,
and other online behaviour;
- deliver, enable, target and optimize advertising and promotional information.
If you wish to “opt out” of targeted advertising, click the information button in one of the advertisements shown through our Games and select to opt out from targeted advertising. You can also opt out from target advertising from your mobile device’s settings. Please note that if you choose to “opt out” it does not mean that you will no longer receive advertising. It just means that the advertising you see displayed will not be customized to you and your interests and may be less relevant to you.
Prevent fraud and ensure acceptable use of our Service
To identify, prevent, and investigate fraud and provide a fair, equal and enjoyable game experience to players, we have a legitimate interest to collect and process necessary personal information to
- analyse use of Games and Service and the behaviour of players to detect frauds and other misbehaviour;
- determine accounts or players connected to fraudulent schemes or other misbehaviour;
- monitor and moderate chat discussions and forum posts either automatically or manually; and
- take actions against fraudulent or misbehaving players.
Please note that our Service offers communication methods like chats or community forums. You need to be aware that any information you provide by these means (also your chat text) is monitored and may be read, collected, and used by others who access the information, for example, other players and us. Please see our Terms of Service for instructions on the acceptable use of our Service.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We may disclose your personal information to the following recipients or categories of recipients:
- Unity Technologies, https://unity3d.com/legal/privacy-policy
Other marketing and social media:
- Facebook, https://www.facebook.com/privacy/explanation
- Vungle, https://vungle.com/privacy/
- Chartboost, https://answers.chartboost.com/en-us/articles/200780269
- AdColony, https://www.adcolony.com/privacy-policy/
- Our service providers and subcontractors who process your information only on our behalf and according to our instructions. These partners provide data processing services to us, for example, to provide (i) data hosting, (ii) marketing and advertising services, (iii) player support, (iv) analytics for Games and Service as well as (v) development and maintenance;
- Any competent law enforcement body, regulatory, government agency, court 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; and
COOKIES AND SIMILAR TRACKING TECHNOLOGY
Like most games and online services, we and our partners use advertising identifiers, cookies and similar tracking technologies. Advertising identifiers, cookies and similar technologies are used by us and our partners to provide our Service to you and to collect data from your device. These technologies allow us and our partners to (i) recognise you and your device; (ii) provide interest-based advertising to you; (iii) prevent fraud, (iv) allow our Service to interact with a third party social network or platform (where you have chosen to allow such interaction); (v) allow our payment processors to process your payment instructions; and (vi) enable us and third parties to provide you with more customized services, for example to provide our Service in the correct language (subject to availability). You can limit ad tracking, reset advertising identifiers and disable cookies from your device or browser settings.
You may also see our own advertisements in other games and services. If you click such advertisements and install our Game(s), we may share a device identifier with our partners to verify installs and prevent fraudulent actions.
HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?
We use appropriate technical and organisational measures designed to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include that only those of our employees, who on behalf of their work are entitled to process personal information, are entitled to use a system containing personal information. Each user has a personal username and password to the system. The information is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and the backup copies are in locked premises and can be accessed only by certain pre-designated persons. We also aim to minimize the personal information that we process, for example, our Games do not require you to register an account with your name and other details. Moreover, we use only advertiser identifiers and other more technical information to recognize players.
INTERNATIONAL DATA TRANSFERS
Our Service is global by nature and therefore 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.
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). Unnecessary and outdated personal information will be erased or anonymized in connection with the periodical reviews and also at other times when deemed necessary.
YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
- If you wish to access, correct, update, request deletion, object to processing or restrict processing of your personal information, you can do so at any time by contacting us. The same applies to portability requests.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
SPECIAL NOTE ABOUT CHILDREN’S PRIVACY
We comply with all applicable laws that are designed to protect children’s privacy, such as the GDPR and the Children’s Online Privacy Protection Act (“COPPA”).
For clarity, our Games are not intended to children under 13 years of age, therefore no one under 13 years of age is allowed to use or access the Games or provide any personal information to us. We do not knowingly collect or solicit personal information from or direct or target behaviourally targeted advertising to anyone under 13 years of age or knowingly allow such persons to use or access our Games. If you are under 13 years of age, please do not send any information about yourself to us including your name, address, telephone number, or email address.
If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us using the contact details provided under the “How to contact us” heading below.
If we learn that we have inadvertently gathered personal information from children under 13 years of age, we will dispose of that information, or otherwise treat it in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under 13 years of age has provided us with personal information, please contact us using the contact details provided under the “How to contact us” heading below.
HOW TO CONTACT US?
The data controller is Small Giant Games Oy, domicile Helsinki, Finland, business ID 2534733-4.