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In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal bases which we rely upon are the following:
- Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested – and that we have agreed – to provide to you, such as our games, customer services, chat functionality and third party social network connectivity;
- Legal Obligation. This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data;
- Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics, research and optimisation of our games and other Services; and
- Consent. This is used as a legal basis in the following contexts: (i) the collection of data stored on your device by us and our advertising partners, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and you can withdraw your consent to this by uninstalling our games; (ii) the storage of data on your device by us and our advertising partners, including through the use of cookies. By accessing and using our Services, you consent to this storage and you can withdraw your consent by updating your cookie settings; and (iii) the use of your data by us and our partners for targeted advertising purposes (for more information, see Marketing and Advertising above). You consent to this collection when you accept this Privacy Policy and you can withdraw your consent to this processing by following the steps at How to adjust your preferences for interest based advertising. Where we ask for your consent to use your data for any other purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent.
In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease playing our games and stop using our Services.
We takes appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.
In addition to the other disclosures described in this Privacy Policy, we will also share your information:
- where we have your consent to do so (including as set out in this Privacy Policy);
- as reasonably necessary in order to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfil the Services or to communicate with you);
- where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment processors);
- where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
- as we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of our users, or others; and
- if there is a sale of the assets or corporate restructuring, or as a result of a change of control of our game or one of its group companies, or in preparation of any of these events. Any third party to which transfers of sells our game assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.
We may also share your information with our service providers if necessary to enable them to provide services to us.
Our Privacy Policy contains further details about:
- Who we share your information with and the reasons for sharing it;
- Measures we take to keep your information secure;
- The legal bases under which we process your data;
- How long we retain your information and where we store it;
- When and why we share your information with third parties, including transfers outside of the European Economic Area (the “EEA”); and
- Changes or updates to our Privacy Policy.
You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.
Those rights include:
- Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why.
- Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.
- Data deletion. You have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.
- Account deactivation. If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items will be lost and we may not be able to restore them in the future.
- Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
- Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below). - Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
- Right to opt-out (California, USA): California residents have the right to opt out of the sale of personal information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. If you opt out of the ‘sale’ of your information, we will not sell your information, including to our advertising partners, but you may still see ads in the game and some of our partners may deliver ads to you, based on information they hold on you. See How to adjust your preferences for interest-based advertising for more information. There are other ways in which you can control the personal information that we collect about you. For instance, you could disconnect your Facebook or other social network account from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone. Finally, you could limit or prevent the use of cookies in your web browsers. More information on all of these options is provided elsewhere in this Privacy Policy.
Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.
Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser.
To provide our games, Websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.
Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to:
- Recognise you and your device;
- Provide interest-based advertising to you;
- Allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
- Allow us to understand how you interact with our websites (for example, where we use cookies such as the Google Analytics cookie on our Websites);
- Allow our payment processors to process your payment instructions; and
- Enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language.
You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device.
If you opt out of interest-based advertising, you will still be able to play our games and you may still see advertising in our games, but those ads will not be targeted using information that we hold about you or which our advertising partners collect about you from our games (subject to the exclusion below for players not in California). However, you may still receive ads based on contextual criteria such as the game that the ad is displayed in, or the region in which your device is located.
For players in California: The California Consumer Privacy Act (“CCPA”) gives residents of the US state of California the right to prevent businesses from selling their personal information to third parties. Please see the Advertising Partners section for more information on how we work with our advertising partners. Sharing information in this way may be considered “selling” for the purposes of the CCPA. We do not “sell” your personal information to third parties for any other purpose. If you would prefer that your personal information is not shared with third parties for this purpose, you can update your preferences in relevant games via the settings menu. If you wish to opt-out of this ‘selling’ of personal information in all our games, you can submit a “Do not sell my personal information” request here.
For players not in California: If you would prefer that your personal data is not processed to receive interest-based ads, you can update your preferences via the settings menu in relevant games. You can also submit an opt-out request for all of our games here. Please note that outside of California, even if you have opted-out of interest-based ads in our games, you may still receive interest-based ads from Facebook. If you would prefer that Facebook does not use your personal data for interest-based ads, you need to log into your account on Facebook and update your settings there.
Opting out of interest-based advertising at a device level: You can choose to prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings. If you live in the USA, the EEA or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for EEA users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).
When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.
Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.
We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our games that might be of interest to you. This includes information such as:
Ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
The games you play and information about how you interact with our games and Services;
Your age, country and region, and gender; and
Other demographic and interests based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
Our games may include advertising for third party products and services.
Our advertising partners collect and use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games.
Our participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. We uses the Consent Management Platform (CMP) with the identification number 28.
Where applicable, we use a CMP to gather consent and permissions for our advertising based activity. Where local laws allow, we may opt you into interest-based advertising by default. You can change your preferences at any time in the setting pages of our games.
We use information that we hold about you to better target ads for third party goods and services to people that might be most interested in them. These ads may be shown to you within our games or Services.
This Privacy Policy does not apply to the collection of your information by our marketing partners. We recommend that you review our partners privacy policies for more information.
When we market our games in media published by other companies, we use various third party marketing partners to assist us on our behalf, and we may share information which we have collected about you with such third parties for these purposes.
Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for our games or services, they will serve you with an ad while you are using other websites and services.
By accepting this Privacy Policy and downloading or continuing to play our games, and unless you opt out of interest-based advertising as explained in this section, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies.
This Privacy Policy does not apply to the collection of your information by our marketing partners. We recommend that you review our partners privacy policies for more information.
- Other information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
- Other information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
- Ad identifiers and other non-personal information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
- The games you play and information about how you interact with our games and Services;
- Your age, country or region, and gender; and
- Other information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.