PRIVACY
POLICY Last updated: June 13, 2022. Effective June 13, 2022.
1.
Introduction
52games Studio
Inc. (collectively, “52games
Studio Inc.”, “us”, “our” or “we”) develops and
publish games for mobile
devices. This Privacy Policy (this “Policy”) describes the
ways we collect, store, use, and disclose the
information, including personal information, and data that our users (“users” or “you”) provide
and any 52games Art Ltd. game
provided on a mobile platform (each a “Service,” collectively,
the “Services”). Additionally, this Policy describes your
rights and choices
concerning your information.
Please
note that the scope of this Policy is limited to information and data collected
or received by 52games Ltd. through your use of the
Services. 52games Studio Inc. is not responsible for
the actions of individuals with no relationship to 52games
Studio Inc. or third-party companies, the content of their sites, the use of
information or data you provide to them, or any products or services they may
offer. Any link to those sites does not constitute our sponsorship of, or
affiliation with, those individuals or companies.
If you do
not want 52games Studio Inc. to collect, store, use,
or share your information in the ways described in this Policy, you should not
use our Services.
2.
Information and Data We Collect from You and How We Collect It
When you
use our Services, you may give us your contact information directly on our
website, generally your name and email address.
Registration
Information: We may also offer you the option to complete a user profile that
is visible to other 52games Studio Inc. users (“Account”). If you
create an Account, you may provide us you name, a username, e-mail address, a
password and other information that helps us confirm that it is you accessing
your Account. We may do this through in-game dialog boxes, which you may choose
to skip. If you sign into the Services with Facebook Connect
we will collect information that is visible via your Facebook account such as:
(1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4)
list of Facebook friends. Your Account may be used to publicly identify you as
part of social features of the Services, which may include user-to-user
interaction, chat or messaging functionality, public leaderboards, head-to-head
competition, and other similar features. The 52games
Studio Inc. username will be public and will be shown to other users, but will
only permit access to information that is considered public or that you have
designated as public in your user profile settings.
We may
also offer you the ability to import your contacts or manually enter e-mail
addresses so that you can locate your contacts on 52games
Studio Inc. and invite your contacts to join you in the Services. We will store
those contacts for purposes of helping you and your contacts make connections
through our Services.
Payment
Information: When you order any good or service through the Services, including
any virtual currency or virtual good, our payment processing service provider
will collect your name, phone number, e-mail address, mailing address, billing
address, and complete credit card information that enables them to receive your
payment. Our payment processing service provider may also retain this information
to enable you to purchase additional items through our Services without having
to re-enter it each time. Please note that purchases from third parties may
also be subject to additional policies
InformationCollected by Customer Support: When you ask for assistance from our
Customer Support team, we will collect and store the contact information you
provide (generally your name and e-mail address), information about your
gameplay or activity on the Services, and your user-name or ID number. We will
also store the correspondence and any information contained within.
Technical
and Usage Information: When you access our Services, we may collect (i) certain
technical information about your mobile device
or computer system, including IP Address, mobile device ID (IDFA, Google
Advertising ID or other identifiers), and the version of your operating system;
and (ii) usage statistics about your interactions with the Services. In certain
Services we will create and assign to your device an identifier that is similar
to an account number. We may collect the name you have associated with your
device, device type, telephone number, country, and any other information you
choose to provide, such as username, character name, or e-mail address. We may
also access your contacts to enable you to invite friends to join you in the
Services. This information is typically collected through the use of
third-party mobile device software development kits. We may occasionally send
you push notifications through our Services to send you game updates, high
scores and other service-related notifications that may be of importance to
you. You may at any time opt-out from receiving these types of communications
by turning them off at the device level through your settings.
3. How We
Use Your Information
52games Studio
Inc.'s primary goals in using your information are to create your account,
provide Services to you, troubleshoot, improve and optimize our Services,
contact you, conduct research and create reports for internal use. We use
information collected through our Service for purposes described in this Policy
or disclosed to you in connection with our Service. For example, we may use
your information to:
- Create
accounts and allow users to use our Services;
- Identify
and suggest connections with other 52games Studio
Inc. users;
- Operate
and improve our Services;
-
Understand you and your preferences to enhance your experience and enjoyment
using our Services;
- Respond
to your comments and questions and provide customer service;
- Provide
and deliver products and services you request;
- Deliver
advertising and marketing and promotional information to you;
- Send you
related information, including confirmations, invoices, technical notices,
updates, security alerts, and support and administrative messages;
-
Communicate with you about promotions, contests, rewards, upcoming events, and
other news about products and services offered by 52games
Studio Inc. and our selected partners;
- Conduct
and administer contests promoted by 52games Studio
Inc.;
- Enable
you to communicate with other users; and
- Link or
combine it with other information we get from third parties, to help understand
your preferences and provide you with better services.
Use of
Your Information by Others:
Third
Party Services. We may provide your information to third party companies to
perform certain services, including but not limited to hosting services,
payment processing, analytics, customer service and to assist us in our
marketing efforts. Where we share your information with third-party service
providers and business partners, we ensure that we have appropriate agreements
in place to protect your information as required by applicable data protection
laws.
Advertising.
To the extent we display advertising in our Services, we may allow advertising
networks of our affiliates and partner networks to collect information about
your mobile device to enable them to serve targeted ads to you. Such mobile
device data includes the following:
- Device
make, model and operating system;
- Device
properties related to screen size & orientation, audio volume and battery;
- Carrier;
-
Operating system;
- Name and
properties of mobile application through which a consumer interacts with the
Services;
- Country,
time zone and locale settings (country and preferred language);
- Network
connection type and speed;
- IP
Address;
- Internet
browser user-agent used to access the Services; and
-
Advertising ID (IDFA on iOS devices and GAID on Android devices).
You may
visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in
the EU) to learn more about interest-based advertising and how to opt-out of
this form of advertising on your web browser by companies participating in the
Digital Advertising Alliance (“DAA”)
self-regulatory program. If you wish to opt-out of interest based
advertising in mobile apps on your device by companies that participate in the
DAA’s AppChoices
app, you may download that app onto your device and exercise your choice. AppChoices
is available at the links below:
DAA AppChoices iOS
DAA AppChoices Android
DAA AppChoices Amazon
You may
also limit data collection by third parties by using your mobile device
settings. Please note that electing to opt-out will not stop advertising from
appearing in your browser or applications. It may make the ads you see less
relevant to your interests. Additionally, please not that if you use a
different browser or erase cookies from your browser, or use a different mobile
device, you may need to renew your opt-out choices.
4. How We
May Disclose Your Information to Third Parties
52games Studio
Inc. does not share your personal information except as approved by you or as
described in this Policy.
We may
share information we collect or derive with third parties for the following
purposes:
- With
service providers that perform services on our behalf, including the ones
referenced above under “Third Party Services”;
- With our
affiliates;
- For
analytics and research purposes;
- When we
have a good faith belief that we have to disclose the information in response
to lawful requests by public authorities, including law enforcement or legal
process purposes;
- To
satisfy any applicable laws or regulations;
- When we
believe in our sole discretion that our Services are being used in committing a
crime, including to report such criminal activity or to share information with
other companies and organizations for the purposes of fraud protection, credit
risk reduction, and other security precautions;
- To
protect our or a third party’s legal rights, investigate fraud, or to defend against a
legal claim;
- As part
of a business transfer such as a merger, acquisition, or at bankruptcy;
- We may
share aggregate or anonymous information about you with advertisers,
publishers, business partners, sponsors, and other third parties; and
- We may
use analytics services provided by third parties, including Google Analytics.
These service providers may use cookies to collect information about your
online activities across this and other sites over time for non-advertising
purposes. To learn more about how Google analytics collects and processes data
and the choices Google may offer to control these activities, you may visit
http://www.google.com/intl/en/policies/privacy/partners/.
5. Specific
Provisions for EU Individuals
This
section only applies to individuals located in the European Economic Area,
United Kingdom, or Switzerland (collectively, the “Designated Countries”) at the time of data collection.
We may ask
you to identify which country you are in when you use or access some of the
Services, or we may rely on your IP address to identify which country you are
located in. When we rely on your IP address, we cannot apply the terms of this
section to any individual that masks or otherwise hides their location
information from us so as not to appear located in the Designated Countries. If
any terms in this section conflict with other terms contained in this Policy,
the terms in this section shall apply to individuals in the Designated
Countries.
Accessing
and Correcting Your Personal Information. At any time, you may contact 52games Studio
Inc. at the address provided in the “Contact 52games
Studio Inc.” section herein and request to access the
personal data that 52games Art Ltd. holds about you. 52games Studio Inc. may need to ask you to provide certain
information to make sure you are who you claim to be. If you find the
information on your account is not accurate, complete or updated, then please
provide 52games Studio Inc. with the necessary
information to correct it.
Withdrawing
Your Consent. Contact us if you would like to withdraw your consent to the
processing of your personal data. Exercising this right will not affect the
lawfulness of processing based on consent before withdrawal.
Erasing or
Restricting Access to Your Information. You may request to delete or restrict
access to your personal data. We may postpone or deny your request if your
personal data is in current use for providing Services or for other legitimate
purposes, in which case we will let you know if we are unable to do so and why.
Transferring
your Personal Data (Otherwise known as Your Right to Data Portability). You
have the right to receive your personal data that you have provided us in a
structured, commonly used and machine-readable format and the right to transmit
that data to another party of your choice, where technically feasible. However,
this right shall not apply where it would adversely affect the rights and
freedoms of others.
Right to
Make Complaint: if you consider that our processing of your personal data
infringes data protection laws, you have a legal right to lodge a complaint
with a supervisory authority responsible for data protection. You may do so in
the EU member state of your habitual residence, your place of work or the place
of the alleged infringement.
If you
have any concerns about the way we process your personal data, you are welcome
to contact our data protection officer at [email protected] or
write to us at the address set forth in the “Contact 52games Art Ltd.” section. We will look into your request and
make good faith efforts
to resolve any concern you may have.
6.
Security Safeguards.
52games Studio
Inc. takes reasonable measures to protect your information from unauthorized
access or against loss, misuse or alteration by third parties. Although we make
good faith efforts to store the information collected on the Services in a
secure operating environment that is not available to the public, we cannot
guarantee the absolute security of that information during its transmission or
its storage on our systems. Further, while we attempt to ensure the integrity
and security of our network and systems, we cannot guarantee that our security
measures will prevent third-party “hackers”
from illegally obtaining access to
this information. We do not warrant or represent that your information will be
protected against, loss, misuse, or alteration by third parties. No method of
transmission over the Internet, or method of electronic storage, is 100%
secure, however. Therefore, we cannot guarantee its absolute security.
7. Data
Retention.
52games Studio
Inc. retains your personal data for as long as needed to provide you Services,
unless we are required by law to delete or if 52games
Studio Inc. accepts your request to delete the information. We will also retain
and use your personal data as necessary to comply with our legal obligations,
resolve disputes, and enforce our agreements.
8. Our
Policy Regarding Children.
We do not
knowingly collect or solicit personal data from anyone under the age of 16 or
knowingly allow such persons to use our Services. If you are under 16, please
do not send any information about yourself to us, including your name, address,
telephone number, or email address. No one under the age of 16 may provide any
personal data. In the event that we learn that we have collected personal data
from a child under age 16, 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 16, please contact us.
9.
Transfer of Personal Data Outside Your Country.
We may
transfer information that we collect about you to affiliated entities, or to
other third parties across borders and from your country or jurisdiction to
other countries or jurisdictions around the world. Please note that these
countries and jurisdictions may not have the same data protection laws as your
own jurisdiction, and we take steps to ensure adequate safeguards are in place
to enable transfer of information to the U.S. and the use and disclosure of
information about you, including personal data, as described in this Policy.
10. Lawful
Basis for Processing.
On certain
occasions, we process your personal data when it is necessary for the
performance of a contract to which you are a party, such as to provide the
Services to you. We may also process your personal data to respond to your
inquiries concerning our products and services.
On other
occasions, we process your personal data where required by law. We may also
process your personal data if necessary to protect your interests or the
interests of a third party.
Additionally,
we process your personal data when necessary to do so for fraud prevention,
improving our network and services, and marketing our services to advertisers
and publishers; where these interests are not overridden by your data
protection rights.
If the
processing of personal data is necessary and there is no other lawful basis for
such processing, we will generally ensure that consent has been obtained from
you. You have the right to withdraw your consent to processing of personal data
at any time.
For
questions about data processing, please contact our Data Protection Officer.
Visit the “Contact 52games Art
Ltd.” section below for
contact information.
11.
Specific Provisions for California Consumers
These
additional provisions for California consumers apply only to individuals who
reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional
rights to know, delete and opt out, and requires “businesses”
collecting or disclosing personal information to provide notice and
a means to exercise those rights.
-
Categories of personal information collected in the preceding 12 months
- Business
purpose for collection
- Third
parties with whom we may share your information
Right to
Know and Right to Delete For any of the personal information described above,
you can request to know what personal information we collected, disclosed, used
and sold, and request that we delete your personal information at any time.
To
exercise your right to know and right to deletion, please submit a request by:
Emailing [email protected] with the subject line “California Rights Request.” We will need to verify your
identity before processing your
request. In order to verify your identity, we will generally require the
matching of sufficient information you provide us to the information we
maintain about you in our systems. In certain circumstances, we may decline a
request to exercise the right to know and right to deletion, particularly where
we are unable to verify your identity.
Upon
verification of your request, we will delete (and direct our service providers
to delete) your personal information from our records, unless retaining the
information is necessary for us or our service providers to complete the
transaction with you, detect security incidents or fraud, fixing errors,
exercise free speech or another right provided by law, comply with legal
obligations, or other internal and lawful uses.
Right to Opt Out of Sale
CCPA gives you a right to direct a business
that sells your personal information to stop selling your personal information
and to refrain from doing so in the future. We do not sell any of your personal
information and will require our service providers not to sell your personal
information.
You also
have the right not to be discriminated against for exercising any of the rights
listed above.
If you are
a California resident seeking to exercise your rights under the CCPA or have
any questions or concerns, please email us at [email protected]. In
certain circumstances, you are permitted to use an authorized agent to submit
requests on your behalf where (i) you provide sufficient
evidence to show that the requestor is an authorized agent with written
permission to act on your behalf and (ii) you successfully verify your own
identity with us.
We aim to
respond to a consumer request for access or deletion within 45 days of receiving
that request. If we require more time, we will inform you of the reason and
extension period in writing.
12.
Changes to This Policy.
We may
update this Policy to reflect changes to our data and information privacy
practices. If we make any material changes we will
notify you by means of a notice on the Services prior to the change becoming
effective. We encourage you to periodically review this Policy for the latest
information on our privacy practices. Please note that if 52games
Studio Inc. needs to adapt the policy to legal requirements, the new policy
will become effective immediately or as required
13.
Contact Us
You may
contact 52games Studio Inc.’s Data Protection Officer at [email protected]