PRIVACY AND DATA POLICY
ISSUED BY Free for Firevincy Studio
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of games and other products developed by Firevincy
Studio (TS/ we / us).
This privacy and data policy (Privacy Policy) applies and has effect in respect of all games, related
online services (including online network play connectivity and interactivity) and other software and
products made available by us (together the Game(s)), as well as any other online features relating to the
Games including our website (the Website). Together the Game(s), and Website are referred to as the Online
Services.
If you have any questions or comments about this Privacy Policy, please contact us at [email protected]
We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on
which personal information we collect from you will be processed by us or on our behalf. Where we decide the
purpose or means for which personal data you supply through these Online Services is processed, we are the
data controller. We will comply with all applicable data protection laws, including the General Data
Protection Regulation 2016/679.
Please read this Privacy Policy carefully as it contains important
information about the following:
What information we may collect about you;
How we will use information we collect about you;
Whether we will disclose your details to anyone else; and
Your choices and rights regarding the personal
information you have provided to us.
This Privacy Policy forms a part of and should be read in conjunction with our terms of use.
The
Online Services may contain hyperlinks to services owned and operated by third parties. These third party
services may have their own privacy policies and we recommend that you review them. They will govern the use
of personal information that you submit or which is collected by cookies and other tracking technologies
whilst using these services. We do not accept any responsibility or liability for the privacy practices of
such third party services and your use of these is at your own risk.
We may make changes to this Privacy Policy in future, which will be posted on this page. You should check
this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of
changes through the Games.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
a) Information provided by you when using the Games
(Basic Information)
We may collect the following information from you when you play our Games:
your mobile devices unique device ID (Device ID);
your user preferences; and
Core information
related to your gameplay, such as your overall progression to a particular level or stage, your virtual
currency stores or the completion of certain activities during your gameplay (for example, completing a
tutorial, passing a level, making a purchase or viewing a video ad).
b) Information used for the purposes of serving advertisements
(Advertising Data)
Through our third party advertising network partners, we may gather information about your devices when
you install or play our Games, depending on the permissions youve granted. This may include:
the make,
model and operating system of your device;
properties of your device, such as screen size and
orientation, audio volume and battery;
the mobile network operator linked to your device;
the Games
played;
the country, time zone and locale settings on your device (i.e. country and preferred language);
network connection type and speed;
IP Address;
MAC address;
internet browser used to access the
Games; and
the advertiser ID, which is an identifier unique to you if you use an Apple or Android
device, but which doesnt reveal your name.
c) Information collected for the purposes of providing
analytics
(Analytics)
We may collect technical information about your use of the Online Services through the use of tracking
technologies and analytics.
Personal data we may collect includes the following:
your Device ID;
your user ID (which is generated by us and allocated to you when you first play our
games);
your device operating system & version;
your device make and model;
game play
attempts, progression and results;
session game time start, end and duration;
purchase transaction
types and spend you have made using virtual items in the Games;
the country of your Device;
the
time, date and install source of your first download (e.g. from a clicked advertisement);
advertisements
viewed and clicked; and
identification of crashes and defects.
d) Information about you collected from third parties
(Third Party Log In Information)
When you access the Games via a third party social media provider such as Facebook, we may collect and
store personal and non-personal information which is available on that third party social media provider,
such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your
friends, provided that you have expressly agreed to the use of Facebook within the Games. We will also
receive technical data in order to ensure the Games connect to the correct Facebook account.
3. WHY WE COLLECT INFORMATION ABOUT YOU
a) To provide our Games to you
We will use information about you (including Basic Information, Third Party Log In Information, Analytics
and User Content) for delivering our Games to you under the terms of use agreed between us. The processing
of information in this way is necessary for us to record your progress and current status within a Game, and
to ensure the Games deliver the features promised and function properly, so that you have the best
experience when playing any one of our Games.
b) To help us improve the Online Services and fix any problems
We may process information about you (including Basic Information, User Content and Analytics) so that we
can analyse and improve our Games and Online Services.
This processing is also necessary for us to pursue
our legitimate interests of (i) ensuring that our Online Services function properly so that you and other
users have the best experience when playing any of our Game(s) and using the other Online Services; (ii)
improving the quality of our Online Services, and providing a better experience to our users; (iii)
identifying and correcting any bugs in the Games and Online Services and iv) understanding the effectiveness
of our marketing to attract new users and re-engage our current users at an aggregated level.
d) To acquire new users and engage current users
We may process information (including some Advertising Data and Analytics) to encourage engagement from
our less active users and to notify them with new virtual items or other promotions on offer.
We may also
process this information to pursue our legitimate interests of acquiring new users for our Games.
We use
various forms of marketing to acquire new users. The information we collect about you may be used to improve
the relevancy of our marketing, including the creation lookalike audiences. This allows us to offer more
relevant marketing to potential new service users without using information that personally identifies you.
e) To improve the monetisation of the Games via in-app purchases
We may process information (including Basic Information, User Content, Advertising Data and Analytics) to
understand how users use our Games, and to compile statistical reports regarding that activity, as well as
understanding how users progress, and their current status within a Game. This processing is necessary for
us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated
via in-app purchases. This may include the implementation of dynamic pricing models, so that in-app
purchases are priced according to relevant factors, such as geography and gameplay progression so that we
can offer temporary promotional discounts.
f) For advertising purposes
We may process Advertising Data to show you advertisements for third party services; including
advertising that may reward you with benefits during your use of the Games.
The information we collect
about you may be used to understand how advertisements placed in our Games have performed or how many people
have viewed certain advertisements. We aggregate this information so that it does not personally identify
you or permit you to be treated individually.
We may also use this information to reward users with
benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed
in our Games.
We will not pass or process your information for the purposes of marketing by third parties
unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at
any time.
We may use the information we collect about you to serve you targeted advertisements in our Games. We do
this to provide you with more relevant advertising content. We work with the following third party
advertising networks :
Chartboost � https://answers.chartboost.com/en-us/articles/115001489623
Adcolony �
https://www.adcolony.com/privacy-policy/
Facebook � https://www.facebook.com/privacy/explanation
Unity � https://unity3d.com/legal/privacy-policy
Google � https://policies.google.com/technologies/ads
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
g) To prevent fraud and illegal activity
We process personal data for our legitimate interests of ensuring that any use of the Online Services is
lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or
other individuals, to enforce our legal rights and to comply with our legal obligations.
Where we
reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use
your personal information to inform relevant third parties such as your law enforcement agencies about the
content.
We reserve the right to disclose your identity to any third party who is claiming that any User Content
posted by you constitutes a violation of their intellectual property rights, or of their right to privacy.
You may not copy, download, or embed any User Content without the express written permission of the content
owner. You may not use any User Content for any commercial purposes, or any public performances.
We work with Apple and Google to assist us with fraud prevention and the detection of any illegal
activity (e.g. to verify in-app purchases made through iTunes and Google Play).
4. DATA SHARING
We will share your information with third parties only in the ways that are described in this Privacy
Policy
Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may
disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its
subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or
subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy.
However, this is on the basis that they do not make independent use of the information, and have agreed to
safeguard it.
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a
portion of its assets, any third party to which we sell or transfer our assets to will have the right to
continue to use the personal and other information that you provide us in the manner set out in this Privacy
Policy.
Required by law: In addition, we may disclose your information to the extent that we are required to do
so by law (which may include to government bodies and law enforcement agencies); in connection with any
legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal
rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We
may also disclose your personal information to third parties in order to enforce or apply the terms of
agreements, to investigate potential breaches, or to protect the rights, property or safety of TS, our
customers, or others.
Digital Content Stores: Where the Games are downloaded through Google Play, iTunes and/or Amazon
Appstore, we may disclose your personal information to Google, Apple and/or Amazon respectively for the
purposes of facilitating any in-Game payments made through these platforms.
5. AUTOMATED DECISION MAKING
We may use automated decision making methods which do not involve human involvement to process your
information only in the ways that are described in this Privacy Policy
We may process your personal
information via automated decision making methods in order to identify users who are suspected of cheating
in the Games. Our automated decision making methods are designed to detect cheating by looking out for (i)
excessive currency stores against actual completed gameplay; and (ii) excessive content against actual
purchases made and completed gameplay.
If users are determined to be or suspected of cheating the
following actions may be taken and which will be unknown to the user:
an increase in the number of advertisements displayed within the Games; and
an increase in the
frequency of suspected cheats playing against other suspected cheats.
We may block users from the Games
and/or the Online Services who are determined to be cheating following an automated decision process. In
this scenario the user will be notified of the outcome and will have the right to obtain human intervention
to express his or her point of view and to contest the decision to block access to the Games and/or the
Online Services.
6. CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to be part of a lookalike campaign, receive notifications from us or be served with
targeted advertisements you can opt-out by changing your advertising and notification settings on your
device directly.
You can withdraw your consent to targeted advertising by changing your advertising settings on your
device at any time.
7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the
table below. We aim to comply without undue delay, and within one month at the latest.
To make a request,
please let our Data Protection Officer know by sending an email to [email protected].
a) Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any
inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct
or delete personal information held about you on our files (and with any third parties to whom it has been
disclosed to).
b) Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
you consented to our
processing the personal data, and have withdrawn that consent;
we no longer need to process that
personal data for the reason it was collected;
we are processing that personal data because it is in the
public interest or it is in order to pursue a legitimate interest of TS or a third party, you dont agree
with that processing, and there is no overriding legitimate interest for us to continue processing it;
the personal data was unlawfully processed;
you need the personal data to be deleted in order to comply
with legal obligations;
the personal data is processed in relation to the offer of a service to a child.
c)
Obtain a machine readable copy of your personal data, which you can use with another service provider
If
we are processing data in order to perform our obligations to you, or because you consented, or if that
processing is carried out by automated means, we will help you to move, copy or transfer your personal data
to other IT systems.
If you request, we will supply you with the relevant personal data in digital
format. Where it is technically feasible, you can ask us to send this information directly to another IT
system provider if you prefer.
d) Make a complaint to a Supervisory Authority
If you are unhappy with
the way we are processing your personal data, please let us know by contacting us via the email.
If you
do not agree with the way we have processed your data or responded to your concerns, an alternative is to
submit a complaint to a Data Protection Supervisory Authority.
8. DATA RETENTION
We will hold your personal information on our systems for as long as is necessary for the relevant
service, or as otherwise described in this Privacy Policy.
9. CHILDREN
We do not use our Online Services to knowingly solicit information from or market to children under the
age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the
event that we learn that we have collected personal information from a child under 13 years of age we will
delete that information as quickly as possible. If you believe that we might have any information from or
about a child under 13 years of age please contact us at [email protected].
10. SECURITY
We will take all reasonable technical and organisational precautions to prevent the loss misuse or
alteration of your personal information. For example, our databases are password protected and limited to
essential employees only (such as TS management or employees whose main role requires system access).
Please
be aware that, although we endeavour to provide reasonable security for information we process and maintain,
no security system can prevent all potential security breaches.
CONTACT INFORMATION
All questions, comments or enquiries should be directed to TS at [email protected] . We
will endeavour to respond to any query or questions within three business days.