Privacy Policy
1.1. This Privacy Policy (“Policy”) explains the ways we collects, stores, uses, or otherwise processes personal data of end users of our Services as defined below (referred to as “you” or “your” in this Policy), and why we collect it, how we use that information, and how you can exercise your privacy rights.
1.2. BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES.
2. DATA CONTROLLER
By “data controller”, we mean an entity that determines how and why personal data is processed. Your personal data will be held by us in accordance with applicable data protection laws.
While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data.
3. WHAT DATA WE PROCESS
3.1. When you access our products and Services, we won’t collect your legally-sensitive data (i.e. race, ethnicity, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sexuality and/or criminality) and other sensitive data (i.e. child data, social security numbers, bank account or payment card details). Please do not provide this kind of information to us or use the Services to make it available to others.
3.2. We may collect user’s data from you, which includes:
- your name, email address, or other contact information if you have provided them to us (for example, when registering an account or subscribing to our communications);
- online identifiers such as your in-game alias, IP address, internal identifiers we assign to your account, or hardware or operating system based identifiers including your Advertising ID or device ID,
- technical information about the device you use to play our Games or use our other Services (for example, information about its type, model, manufacturer, operating system, language, display, processor, or memory),
- your coarse location (for example, country, state, or city), inferred from your IP address,
- information about your use of the Services (for example, information about your progress in our Games, your visits to our Websites, or your interactions with ads in our Games),
- information about your interactions with our ads outside of the Services (for example, on third-party websites or applications), including information on how you were referred to our Games or other Services,
- crash logs or other information related to bugs, errors, or other issues in our Services,
- messages or other communications you send to us or through the Services (for example, your chat messages in our Games or emails you send to our support team),
- if you choose to connect a third-party account (for example, a social media account) with our Services, information we receive from the third-party account provider (for example, an account name, identifier, or email address to enable cross-device gameplay or a profile name, picture, or friends’ information to provide social features),
- if you make purchases in our Games, information we receive from third-party payment service providers to validate those purchases (but not your actual payment information such as credit card numbers),
- if you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so (for example, information about your background or experience with our Games),
- any other information you choose to submit to us through our Services or otherwise, andwith your consent, other information explained to you when asking for your consent.
4. HOW WE COLLECT YOUR DATA
We may collect and receive information which may be considered personal data according to applicable laws in a variety of ways. More specifically:
- directly from you when you submit it to us (for example, when registering an account with us, subscribing to our communications, sending support enquiries to us, or responding to our surveys),
- directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services (for example, on third-party websites or applications), including through cookies or similar technologies or software development kits (SDKs),
- from our advertising partners involved in the delivery and measurement of ads when you interact with third-party ads in our Games outside of our Services (for example, on third-party websites or applications),
- if you choose to connect a third-party account (for example, a social media account) with our Services, from the third-party account provider,
- if you make purchases in our Services, from the third-party payment service provider involved in those transactions, or
- with your consent, from other sources explained to you when asking for your consent.
Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this Policy, depending on the Services you decide to use and your choices when using them.
You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games, use your device settings to reset or limit the use of your Advertising ID, withhold consent for customized advertising, or disable some or all cookies from your browser settings.
5. WHY WE COLLECT YOUR DATA
5.1. GENERAL
When we process or collect your data, we ensure that we have a legal basis to do so. Below, you can find examples of the different purposes for which we process your data and the legal basis we have for each of those reasons:
- to carry out our obligations as a result of any contract entered into between you and us and to provide you with the information and services that you request from us, including to set up, manage and administer your betting account (including for anti-money laundering, prevention of terrorist financing, processing any self-exclusion requests and identity verification purposes) and to make, settle and pay bets;
- to notify you about changes to the products and services that we offer and (where you have indicated your consent) to directly market these products and services to you;
- to administer our websites for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to allow you to participate in interactive features of our products and services (including our casino products);
- as part of our efforts to keep our products and services safe and secure;
- to measure or understand the effectiveness of our advertising and marketing;
- to operate and improve our products and services;
- to set up and maintain your registration with the Service;
- to improve customer service;
- to provide features available in the Service;
- to audit and analyze the Service;
- to ensure the technical functionality and security of the Service;
- to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- for statistical and research purposes (including market research, marketing and data analysis purposes);
- to identify your betting behaviour, habits and preferences;
- to analyse your credit risk (if applicable);
- to handle payment and collection processes to and from customers;
- to ensure the effective operation of software and IT services procured by us (including disaster recovery);
- for anti-money laundering, prevention of terrorist financing, and identity verification purposes; and to comply with licensing and regulatory requirements that are applicable to us; and for other reasons with your consent.
5.2. MARKETING
Marketing refers to advertising, one of the tools that helps fund our Services and enables us to make our Games available free of charge. In some of our Games, we may show our own ads and also ads from third parties. We also advertise our Games outside of our Services on third-party properties such as websites or applications. This section provides more information on how we may use your data for advertising purposes, and how you can control the use of your data for these purposes.
Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses or other identifiers. An “Advertising ID” is an alphanumeric string of digits provided by the operating system of your mobile device (e.g. your phone or tablet). It is consistent across applications from different publishers. The Advertising ID is known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices. Advertising IDs are used for interest-based advertising and other advertising related purposes. You can control the extent to which your Advertising ID is used for these purposes. Using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising ID. For example, you can “limit ad tracking” on iOS devices or “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them as you prefer on each of your devices individually. It may take some time for your updated settings to take effect.
Please consider that resetting or limiting the use of your Advertising ID will not stop you from seeing ads or necessarily reduce the number of ads you see, but the ads you see may be less relevant to you and will not be served based on your personal data.
1) When you see ads in our Games, we may share your Advertising ID and IP address with our advertising partners if you have given your consent to the use of your data for personalized ads. Our advertising partners may also collect non-personal information directly from our Games through technologies such as software development kits (SDKs). In each case, they may use such data for a number of purposes, including to limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID). For more information, please refer to the privacy policies of our advertising partners listed here.
2) When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID, have determined that you may be interested in our Services. When ad-networks use your Advertising ID in these ways, they do so based on their respective privacy policies or notices.
Ad networks may also use your data to:
- limit the number of times you see our ads,
- inform users who have previously played our Games about new content, updates, or other news related to those Games, or
- refrain from showing our ads to users who already play the Game being advertised.
3) For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as total views, clicks, or installs generated by an ad. Measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as web beacons inserted into ads. This data is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.
6. HOW DO WE KEEP YOUR DATA SECURE?
We take the security of your Personal Data very seriously. We implement the appropriate technical and physical safeguards to ensure that your Personal Data is protected against accidental or unlawful loss, destruction, alteration, unauthorized access or disclosure, or any other use or unlawful processing of Personal Data you have provided to us. Our security mechanisms for Personal Data are similar to those of other game developers. Please keep in mind, though, that the Internet is not 100% secure and any access, disclosure, alteration or destruction of the Personal Data you have provided through our games due to breach of our safeguards cannot be guaranteed.
7. YOUR RIGHTS
You have various rights in relation to the data which we hold about you. We have set these out below.
The EU General Data Protection Regulation (“GDPR”) gives you the following rights in relation to your personal data:
7.1. Right to access your Personal Data.
You have a right to know what Personal Data we hold about you, how and why we handle your Personal Data. You can ask us for a copy of your Personal Data and in some cases to have the information communicated to you. If you would like to exercise your right of access please contact us as described below and let us know 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 endeavour to tell you why.
7.2. Right to correct or update your Personal Data.
You have a right to request an update or correction to any of your Personal Data which is out of date, incomplete or incorrect.
7.3. Right to delete your Personal Data.
In certain specific circumstances, you have a right to ask us to delete your Personal Data which we are holding about you. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. If you would like to ask us for further information on the specific circumstances, and who the other recipients are, and/or exercise your right to erasure please contact us. Please note some things can only be deleted when you delete our games from your mobile devices and clear our cookies from any device that you have used for our Services. In that case you will permanently lose all your game progress, Virtual Currency and Virtual Goods without the right to data recovery or refund. Where we delete Personal Data 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 network.
7.4. Right to restriction of processing your personal data.
In certain specific circumstances you have a right to object to the processing of personal data about you which is processed on the grounds of legitimate interests.
7.5. Right to object at any time to processing of your personal data when processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
7.6. Right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt-out it you will still receive advertising, but not direct or target interest. On Apple you can opt-out this by going to Settings > Privacy > Advertising and turning on “Limit Ad Tracking”.
7.7. Right to portability of your personal data. 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.
7.8. Right to withdraw your consent at any time if we are processing your personal data with your consent.
7.9. 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.
7.10. In some instances, our use of your Personal Data may result in automated decisions being taken (including profiling). Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without our human review. For example, we use automated decisions to provide direct or targeted interest-based advertising on our Services.
8. USER DATA DELETION
The user of has the authority to manage, use and delete the data generated in the application. If the user no longer needs the account data in the app, the user can delete or remove it.
Data range that can be deleted: 1) The basic information of the user's Facebook account obtained by the application; 2) User account login record; 3) All user operation records in the app, such as level records, purchase records, etc.
There are notes users should be aware before deleting or removing users. Depending on users' account, deleting, or removing users may have the following effects: 1) The application will delete all user data; 2) Before deleting the user data, you may need to transfer some data; 3) The system will not delete certain data, such as application-related content shared by users on Facebook; 4) After user data is deleted, it cannot be recovered.
Steps to delete the data in the app: 1) Go to your Facebook profile, and find Apps and Websites page at the Facebook Settings; 2) Remove our app; 3) Click the Removed sub-tab, find our app, and Send Request to delete data.
9. CONTACT US
If you have any questions or concerns about this Privacy Policy or any other issue with your personal information while using our Services, please feel free to contact the support team of the Game you play by the email address (xgames798@foxmail.com) listed here.