Effective: December 10, 2020
We use the broad interpretation of a term “Personal Information,” which includes combined definitions pf personal information from CCPA, COPPA, and GDPR. We treat any information relating to an identified or identifiable data subject as personal to the broadest extent. It includes but not limited to the information that identifies, relates to, describes, is capable of being associated with, or may reasonably be linked, directly or indirectly, with a particular consumer or household. We also treat pseudonymous data and depersonalized identifiers as Personal Information if they allow in combination to establish a link between such information and a patricidal consumer, or household, or if they can be used to recognize a user over time and across different websites or online services. The complete list of the Personal Information that the Company processes is included in Schedule A below. Please note that the Schedule A is not applicable to children’s Personal Information.
- California Consumer Privacy Act (“CCPA”):
- Children's Online Privacy Protection Rule ("COPPA")
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or “GDPR”)
- ONLINE PRIVACY OF CHILDREN
- The Company adheres to the principles of the COPPA, a U.S. law designed to protect the online privacy of children, in our Services that are directed to children. If you would like to learn more about COPPA, you can refer to the “Children’s Privacy” section of the Federal Trade Commission’s website.
- The Company adheres to the principles of the GDPR, an EU law designed to protect and empower the owners of personal data (“data subjects”), in terms that regulated the privacy of children.
- In our Services directed to children users, we collect information which includes persistent identifiers such as a device identifier (“device ID”) or an Internet Protocol address (“IP address”). This information is collected solely for the purpose of providing functionality and support for our internal operations and optimizing our users’ game experience. We never collect precise geo-location data from children and do not allow practices and/or mechanisms that mislead them into sharing such information.
- The Company does not permit behaviorally-targeted advertising to children in the Services where we do not have the substantial confirmation that the user is over the age of 13 (thirteen).
- If we decide to change our policy regarding collection of Personal Information of children, we will receive your prior verifiable consent in all cases before such the collection.
- In case we detect the unintended collection of Personal Information from children, including cases when children voluntarily share their information, we may use this information only to respond directly to a child’s specific one-time request. COPPA permits not to make a direct notification is this case. We will not use the information to contact the child again and we will delete it after we respond to the request. In all other cases we will:
- notify parents we collected their online contact information;
- notify parents we collected their child’s online contact information;
- notify parents the online contact information will not be used for any other purpose other than the one as determined in notification and will not be disclosed or combined with other information;
- notify parents that if they do not opt out, we may use the child’s online contact information for that purpose; and
- If you believe that we may have unintentionally collected your child’s Personal Information without your prior consent, you may contact the Company’s Privacy Officer by contacts stipulated in Section 10..
- INFORMATION COLLECTED
- THE COMPANY’S POLICY IS NOT TO COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF 13 (THIRTEEN) YEARS OLD FOR THE UNITED STATES AND OTHER COUNTRIES, OR 16 (SIXTEEN) FOR THE EURIPEAN UNION, UNLESS OTHERWISE ESTABLISHED BY NATIONAL LAW.
- There are two types of information that may be collected by the Company:
- the first is called Personal Information which is information that can be used to identify a specific individual. As stated in the previous section, the Company does not knowingly collect any Personal Information from children outside of the information and required for the support of internal operations. In this case we use the “email plus” method, when we send an email to the parent or legal guardian and have them respond with their consent. Then we send a confirmation to the parent via email, letter, or phone call. In this case we also let the parent know they can revoke their consent anytime. The Company may collect Personal Information that parents, legal guardians or persons 13 (thirteen) years old or over voluntarily provide via the Services.
- We may combine the non-personal information and Personal Information of people above 13 (thirteen) years old for the United States and other countries, or 16 (sixteen) for the European Union, unless otherwise established by national law that we receive through our Services. Information collected will vary depending upon the activity and may include your name, email address, phone number, mobile number, device type, operating system, home address, birth date, statistical and usage data (as further explained below), proof of identify (such as the Social Security, Social Identification Number or Social Insurance Number) of contest prize winners and, to the extent required to process any payment, your credit card information. In addition, we may collect demographic information such as gender, zip code or postal code and other data that you may provide in surveys or online profiles, for instance. We may combine demographic information with Personal Information.
- For EU only: per requirements under GDPR, we log your consent state for compliance purposes. This information is stored on servers hosted in the EU and is used solely for GDPR compliance. The device identifier is stored along with the consent status. If you consent to personalized advertising, your device advertising identifier also is stored in case we need to be able to access it to assist you with data portability or erasure requests. Your device advertising identifier is not stored in our consent logging database if you do not consent to personalized advertising.
- data about your game progress;
- your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
- data about your device, such as device name and operating system, browser type and language;
- general location data;
- precise geo-location data (GPS, only for users above 13 (thirteen) years old for the United States and other countries, or 16 (sixteen) for the European Union, unless otherwise established by national law and with their direct consent);
- data about your use of our application, such as gameplay data and interactions with other players (if applicable and only for users above 13 (thirteen) years old for the United States and other countries, or 16 (sixteen) for the European Union, unless otherwise established by national law).
- When required by law, the Company reserves the right to disclose your Personal Information to third parties or regulatory, law enforcement or other government authorities.
- Google AdMob https://policies.google.com/technologies/ads
- Unity and Unity Analytics https://unity3d.com/ru/legal/gdpr and https://unity3d.com/ru/legal/privacy-policy
- Unity Ads https://unity3d.com/legal/privacy-policy
- Clever Ads Solutions (ClearInvestHouseAds) https://cleveradssolutions.com/privacy-policy
- Firebase Analytics https://firebase.google.com/support/privacy and https://policies.google.com/privacy
- AppLovin https://www.applovin.com/privacy/
- ChartBoost https://answers.chartboost.com/en-us/articles/200780269
- Vungle https://vungle.com/privacy/
- StartApp https://www.startapp.com/policy/privacy-policy/
- Kidoz https://kidoz.net/privacy-policy/
- AppBrain https://www.appbrain.com/info/help/privacy/index.html
- SuperAwesome https://www.superawesome.com/privacy-hub/privacy-policy/
- InMobi Ads https://www.inmobi.com/privacy-policy/
- My.com https://legal.my.com/us/mytarget/privacy/
- Mobfox https://www.mobfox.com/privacy-policy/
- Facebook Ads https://developers.facebook.com/docs/audience-network/policy/
- AdColony https://www.adcolony.com/privacy-policy/
- ironSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
- Verizon Media https://www.verizonmedia.com/policies/us/en/verizonmedia/privacy/
- Amazon Advertising https://advertising.amazon.com/legal/privacy-notice
- Yandex Ads https://yandex.com/legal/mobileads_sdk_agreement/
- PURPOSES FOR WHICH WE USE THE INFORMATION COLLECTED
- We do not collect your children’s Personal Information. Therefore, this section foes not apply to children’s Personal Information. If such collection occurs in future, we will notify you and obtain your prior verifiable consent. We will endeavor to prevent collection of such information and timely notify you in case of accidental collection.
- The Company may use the Personal Information you provide us for the purposes of:
- administering contests and awarding prizes which are only directed to parents and adult users;
- warranty registration and/or providing customer support or responding to technical service requests;
- providing online services for parents and users over 13 (thirteen) years old for the United States and other countries, or 16 (sixteen) for the European Union, unless otherwise established by national law;
- registration for games or special game-specific event participation for parents and users over 13 (thirteen) years old for the United States and other countries, or 16 (sixteen) for the European Union, unless otherwise established by national law;
- registration for membership and participation on our site;
- processing your order(s) of products or subscriptions from us online;
- enabling your use of our software or online services and access to certain areas of our site, features or programs;
- newsletter sign-up; or
- improving our products and services.
- You are not required to provide Personal Information to us to obtain access to any of our Services; however, the collection, use and disclosure of your Personal Information may be required for registration to access certain areas or features of our Services and, if you do not provide the required information, you will not have access to these areas or features.
- Statistical and Usage Data: when you use our Services on your device, we may retrieve information about your hardware system and how your game is played, including your IP address or device ID. We may also collect information about your computer, hardware, software, platform, media, connection, information about online activity such as feature usage, game play statistics and scores, user rankings, click paths, and in-app purchases. We use this information to enable you to play our game over the Internet. We also use this information to better understand preferences of our customers, so that we can improve our products and services.
- Other Uses: we may also use your information for other legitimate business purposes. We will only collect information to the extent reasonably necessary to fulfill the purposes for which it was collected and our legitimate business objectives or as permitted or required by law.
- Internet Protocol Address: we collect an IP address from every visitor to our Services. An IP address is a number that is automatically assigned to your computer or device when you use the Internet. We use IP addresses to help diagnose problems with our servers, administer our Services, analyze trends, track users' movement on our Services, gather broad demographic information for aggregate use in order for us to improve the Services, and deliver customized, personalized content. We do not link IP addresses with any personally identifiable information.
- In-Game Advertising: our Services may incorporate dynamic advertisement serving technology offered by our ad provider (Adwords), which enables advertising to be temporarily uploaded into the game and replaced while you play. The data collected for this purpose may include IP address or players’ user name, downloaded or purchased Services, in game location, length of time an advertisement was visible, size of the advertisements, and angle of view. The Services you are using may be assigned an ID number, which is stored on your device, and used by our Ad Provider to calculate the number of unique and repeat views of dynamic in-game advertising. THE ID NUMBER IS NOT ASSOCIATED WITH ANY PERSONAL DATA AND FOR CHILDREN-DIRECTED SERVICES IS NOT USED FOR BEHAVIORAL ADVERTISING PURPOSES. NONE OF THE INFORMATION COLLECTED AND USED FOR ADVERTISING PURPOSES IS USED TO PERSONALLY IDENTIFY YOU OR YOUR CHILD. WE DO NOT EMPLOY BEHAVIORAL ADVERTISEMENT FOR CHILDREN. The servers used by the ad provider may be located outside your country of residence. This ad serving technology is integrated into the Services; if you do not want to use this technology, do not use our mobile applications while connected to the Internet.
- In accordance with the General Data Protection Regulation (GDPR), the Company’s advertising partners in the European Economic Area all function as independent data controllers. Prior to showing a personalized advertisement, you will be asked whether you consent to sharing your information with the advertising company. If you are a resident of an European Union member state and indicate that your child is below the age of 16 (sixteen) or a lower age established in your member state but not lower than 13 (thirteen) years old, your child will be served non-personalized ads and the advertising companies will not collect Personal Information from your child.
- HOW WE SHARE OR DISCLOSE INFORMATION
- The Company may share your information with third parties for the limited purposes described below. This Section does not concern any child’s Personal Information, to which provision of Section 3. is applicable.
- Partners: the Company may also share non-personal information with our brand partners, which may include without limitation game session information, retention, purchases, gameplay events and user behavior. The Company does not share any Personal Information with these partners.
- Marketing: The Personal Information you provide will allow us to alert you to new products, features and enhancements; special offers; upgrade opportunities; and contests and events of interest. From time to time, we may also inform you on other companies and organizations that provide products or services that we believe may be of interest to you. We see this as a value-added service helping you to find useful products or services. We strive to limit use of the information you provide to those offers that we think you would appreciate receiving. You may opt out of this service by contacting us as set out in the opt-out provision below.
- Legal Rights and Obligations: Finally, we may use and/or disclose your Personal Information to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage. When necessary, we may also disclose Personal Information to law enforcement, or to the appropriate civil authorities.
- YOUR RIGHTS
- You are not required by law to provide us with certain Personal Information. You can always refuse to provide certain Personal Information; however, you acknowledge that such refusal may prevent you from engaging in certain activities within Services or from engaging with Services completely.
- Under the GDPR, you have various rights in relation to your Personal Information. All of these rights can be exercised by contacting us via email designated in Section 10.. In certain circumstances, you have the following rights in relation to your Personal Information:
- Right of access
You have the right to obtain from us information as to whether your Personal Information is being processed, and, where that is the case, access to such personal information. You may access and amend your Personal Information, request the details about purposes of processing of your Personal Information and prevent undesirable marketing by opting-out. If you wish to opt out of marketing, use ‘unsubscribe’ option available at our emails.
- Right to withdraw consent
When we rely on your consent for the processing of your personal information, you have the right to withdraw your consent at any time. However, the withdrawal of your consent will not affect the lawfulness of the Company’s processing based on consent before your withdrawal.
- Right to rectification
We will use reasonable endeavors to ensure that your Personal Information is accurate. In order to assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by sending us a request to rectify your Personal Information where you believe the Personal Information that we have is inaccurate or incomplete.
- Right to restriction of processing
You have the right to ask us to stop processing your Personal Information at any time.
- Right to erasure
Asking us to delete all of your Personal Information will result in the Company deleting your Personal Information without undue delay (unless there is a legitimate and legal reason why we are unable to delete certain of your personal information, in which case we will inform you of this). Asking us to stop processing your Personal Information or deleting your Personal Information on may mean that you will no longer be able to use our site.
- Right to information portability
You have the right to request that the Company provides you with a copy of all of your Personal Information and to transmit your Personal Information to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so and the processing is based on consent or contractual performance.
- Right to complain
Although we encourage our customers to engage with us in the event, they have any concerns or complaints, you have the right to lodge a complaint to a supervisory authority.
- Right to object automated processing
You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you. There may be exceptions or limitations to this right as defined under relevant data protection laws. We will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above, however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. When you request us to rectify or erase your Personal Information or restrict any processing of such information, we may notify third parties to whom such Personal Information has been disclosed of such request. However, such a third party may have the right to retain and continue to process such Personal Information in its own right, for example, to enable it to comply with its own legal obligations.
- Right to make a request
You may also send a request to receive the information which is being processed, amended, deleted or locked and information about any parties to which we transmit your personal information.
- In some cases, we may charge a fee (based on our reasonable costs) if the requests are excessive considering the nature of the request itself or nature and functionality of our services.
- The Company does not discriminate against a consumer who exercises any of the consumer's rights under the CCPA. However, the Company may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided to the consumer by the consumer's data and may offer financial incentives to a consumer for the collection, sale, or deletion of personal information on a prior opt-in consent basis.
- COOKIE AND SIMILAR TECHNOLOGIES
- Cookies enable us to capture how you arrived at our site, when you return, which pages on our site you visit, and to recognize that you are already logged on when we receive a page request from your browser.
- We will never share this information with any third party. Cookies are readable only by us and do not contain any Personal Information nor do they contain account or password information. We cannot and will not gather information about other sites you may have visited.
- OTHER IMPORTANT INFORMATION
- Opt-In Provision: pursuant the GDPR requirement, we are entitled to process any personal information only upon receiving your direct consent and only for the purposes that you provided your consent for. Therefore, you are always entitled to decide if you wish to share any information with us. We do not enable opt-in blockers that prevent you from using the Services without giving your consent. We also do not embed opt-in possibilities in child-oriented elements of our Services so they would be unable to give their consent for collection of personal information. Such consent can be obtained by us only from you.
- Opt-Out Provision: currently, the Company does not share personal information with third parties for marketing purposes. In the event this was to happen, the Company would obtain your consent prior to any such disclosure. If you do not want the Company to send you postal mail about our products and services, you can opt out at any time and choose to have your name removed from our mailing list. Under the GDPR you have a right to have the Company and our third-party partners erase the personal information we have collected from you without undue delay. You can do so by contacting Clear Service’ Privacy Officer as envisaged in Section 10..
- Under the GDPR you have a right to request a copy of the personal data the Company and our third-party partners have collected from you.
- Business Transactions: we reserve the right to transfer any personal information we have about you in connection with the sale or transfer of all or a portion of our business or assets or rights relating thereto.
- If we have unintentionally collected and stored any personal information from children, parents can request access to review such information, have it deleted, or stop our further collection or use of such information. To make any of these requests, please use the contact information below.
- CONTACT INFORMATION
- by e-mail: [email protected]
- by mail: 103 Sham Peng Tong Plaza, Victroria, Mahe, Seychelles
PERSONAL INFORMATION PROCESSING PURPOSES AND DETAILS
Contracted Business Purposes: Advertising, marketing, CRM, payment processing and other business managements services
Personal Information Categories: This Policy involves the following types of Personal Information, as defined and classified in CCPA Cal. Civ. Code § 1798.140(o).
Processed under this Policy
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some Personal Information included in this category may overlap with other categories
C. Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)
D. Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
E. Biometric information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data
F. Internet or another similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
G. Geolocation data
Physical location or movements
NO (can be YES only with your direct consent)
H. Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information
I. Professional or employment-related information
Current or past job history or performance evaluations
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.