Privacy Policy This privacy policy is effective as at 01.01.2017. 1. About us and this policy This policy describes how we and our other group companies (referred to collectively in this policy as 'OpenMyGame' or 'we', us' and 'our') collect, use, process and share information that OpenMyGame collects about you. Our business is constantly evolving and so this document may change from time to time. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us. This policy applies to all of our games, whether played on our website, on mobile devices, PC or on other platforms such as Facebook. It also applies to our advertising activities on all platforms as described below and other services that we may provide to you from time to time. In this policy we refer to our games, websites, advertising activities and other services collectively as our "Services". For information collected under this policy, the data controller is OpenMyGame. By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the use of your information in accordance with this privacy policy. If you have any concerns about providing information to us or it being used as described in this privacy policy you should not use our games or other Services. As set out in the terms and conditions relating to our Services, you must be at least 13 years old to access and/or use our Services. We do not knowingly collect personal data about children under the age of 13. 2. What types of information do we collect We collect information from a number of different sources, but most of it comes directly from you when you play our games, or interact with our websites, advertising or other Services. Broadly the information we collect about you relates to the type of device you are using, how you play our games (such as levels attempted and purchases made), other games or apps you use on your device and may include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests. In more detail, depending on which of our Services you interact with we may collect and process the following types of information: - details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our website(s), what device you use to access our games and services; - information that you provide us with when you fill in forms, answer questions or complete surveys when using any of our Services, when you create an account with us or if you invite your friends to use our games and Services; - the content of messages sent using our chat and messaging systems; - your interactions with us on our social media channels; - information we collect via cookies and other similar technologies, as explained further below; - information we collect from you when you connect our games or Services to third party platforms or social network services or use other social or player-to-player functionality; and - information we collect about you from our other group companies or other third party companies (including publishing partners, platforms, advertising platforms and partners and data aggregators) which may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use this information as described in this policy subject to any limitations in the privacy policy of the company that collected the information from you. In some instances, when you make purchases on or through our website(s), we may collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by OpenMyGame. We do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful. When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play) we do not collect or store any payment information from you. Finally, we may collect some of the information types referred to above on an aggregated or anonymised basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our Services operate and are used. 3. Playing our games socially Connecting with third party social networks You can choose to log into your OpenMyGame Profile using your Facebook account details. If you do this, you will be able to use your Facebook account to log in on multiple devices and synchronise progress across those devices. We will receive some of your Facebook account information and exactly what information we receive will depend on your settings in your Facebook account. We may use this information for the purposes described in this privacy policy, including in order to advertise to you. Once connected in this way, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress). This may also allow you to access other functionality in our games and other services, such as inviting friends to play, asking other players for lives and 1-2-1 messaging. Logging in with Facebook will not allow us to post anything to your Facebook page without your permission. In the future we may also allow you to associate your OpenMyGame Profile with other social network accounts and use your log in details for that account to log into your OpenMyGame Profile. Where we do this, either we or your social network service provider will let you know what information we will receive about you from that social network. If you choose to play our games online on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your OpenMyGame account. You can control how your Facebook information is used and shared with your Facebook friends in your Facebook account settings. Where you connect or associate your OpenMyGame Profile with any third party social network or platform, that social network applications or platform will provide certain information about you to us. These social networks and platforms are created and maintained by a third party which is not a part of, or controlled by OpenMyGame. We may use this data for the purposes described in this privacy policy, including in order to advertise to you. You should ensure that you read the third party social network or platform's terms of service and privacy policies to understand how they treat your data and what information they might share with us. You can make changes to what data a third party social network or platform shares with us, or stop our Services interacting with that social network or platform by adjusting your settings with that third party provider, however you may find you are not able to enjoy all of the same features of our Services. 4. How do we use the information that we have about you? We, our suppliers and group companies may use the information we collect about you for a number of purposes. These include providing our games and other services to you, optimising the games and services we provide, enabling in-app purchases, storing your progress through our games, enabling social network integration, providing customer service support when you need it. We also use your information in connection with our advertising purposes. For more information, see below. We may also use your information for research or analysis. Finally, there may also be other reasons why we need to use your information, such as maintaining records or protecting our legal rights. A more detailed description of how we use your information is set out below. Providing and optimising our Services We use your information to enable us to provide our games, websites, advertising and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our games work properly on all devices and are as enjoyable as they can be for all our players. Chat Some of our Services include player-to-player chat functionality. Users of our chat service(s) can send messages to other registered players. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history. We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose. Marketing and promotion We may use your information to send you direct marketing and promotional materials relating to our Services or related products, for example sending you communications (including by email) for these purposes on our, or a third party's behalf. For example, we might send you information about merchandise relating to our Services. If you do not want us to use your information in this way please let us know by contacting us at [email protected]. Customer Services We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and services. Finally, we will use your data to manage your account and relationship with us and improving your experience when you use our Services. Analytics and Research We use analytics tools, which may include third party analytics tools, to collect information about how you play our games and those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services, or to test out new game features and content. Social and Community We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels. Competitions From time to time we may run competitions, including in games and via our community channels. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition.We may also publish the names and entries of competition entrants. Cheating, crime and fraud prevention We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police. Legal uses We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you. 5. Advertising and promotion What adverts you may see as a result of playing our games or using our Services We promote our own games and services in a number of ways. That might include cross promoting one of our games while you are playing a different game of ours. It might also include advertising our games within websites and other media published by others, or sending you marketing materials by email. Like many companies, we may use information about you in connection with advertising. This includes using information that we have about you, such as the games you play, to try to make sure you only see advertising that might be of interest to you. We may also use the information that we have about you to help a third party deliver advertisements that are tailored to you based on a determination of your characteristics or interests by us based on the information that we have about you. As well as advertisements for our own goods and services, we may also facilitate third parties to optimise their advertising of their own goods and services by helping them to target those ads to those that might be most interested in them. These advertisements may be shown within our games or within websites and other media which are published by others and optimised by us or using our information. This is done using anonymised information and we won't hand over or sell any of your personal information to third party advertisers. We will also use information about your particular device in order to show you adverts which work properly on that device, or to measure the effectiveness of our ad campaigns and we may also retain information about how many times you have seen a particular advertisement so we can stop you from seeing it too many times. Advertising partners When we advertise our games in games or media published by other companies, we may use various third party advertising partners, including ad exchanges, ad networks and ad servers. Our advertising partners help us to serve advertisements to you. Some of this technology also helps us to make decisions as to whether or not to show a particular advert to you - for example, by informing us that you have shown an interest in similar goods or services previously. Our advertising partners may collect information about you when you use our services or the services of others. This Privacy Policy does not apply to the collection of your information by our advertising partners, and we therefore recommend that you review their privacy policies for more information. You can find out more in "How to adjust your preferences" below. How do ad identifiers, cookies and similar technologies work? Advertisers on mobile devices sometimes use advertising (or ad) identifiers to enable and optimise their advertising. Ad identifiers are non-permanent, non-personal device identifiers such as the Android advertising ID and/or Apple's ID for advertising, or IDFA. See below for you can reset these identifiers or indicate your preference that they should not be used for advertising purposes. We and third parties who advertise on our Services may use cookies or similar technologies such as tracking pixels in their advertising. These technologies operate either by: (i) placing a small file which stores some information on your computer or mobile device; and/or (ii) by accessing information on your device. These technologies allow the collection of data, such as your device's model, operating system and screen size, the other applications installed on your device, and information about how you use our services. How to adjust your preferences 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. You can disable cookies through your web or phone browser settings. Although we and our advertising partners use ad identifiers, cookies and similar technologies to enable us and third parties to provide more relevant advertising to you, these technologies also: - allow us to recognise you and your device; - allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction); - 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. As a result, if you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our services. Please note that adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests. Alternatively, if you do not wish us to collect data as described in this section, you should stop using our services. 6. Who else can see your information? In addition to the other disclosures described in this privacy policy, we will also share your information as described in this section. We will 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 on an anonymous and aggregated basis, meaning you could not be personally identified from it; - when you submit information as part of a competition or otherwise interact with our social media channels (for example, by providing a testimonial about one of our Services) we may publish the information you submitted, alongside your name and home country on our website(s) and social media channels; - 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 OpenMyGame, our users, or others; Our games and our websites include social features that enable you to interact with other players. These features will enable other players to see your username, your avatar and your progress through our games and other game play related information such as high scores. Depending on your settings in your social network or OpenMyGame account, other information in your profile may be shared with other players. Also, other players will be able to see anything that you post to any public page, forum or other similarly open feature in our games, websites, community channels or other Services. We may share your information with our service providers if necessary to enable them to provide services to us. 7. Your rights in relation to your information You have certain rights in connection with your personal information and how we handle it. Details of those rights and how to exercise them are contained in this section. You have certain rights in relation to the personal information that we hold about you. 8. How long do we keep your information and where do we store it? We will keep your information for as long as we consider necessary for the purposes described above, or as long as the law allows. We store your information on servers that we control which are primarily based in the European Union. We may also use servers that are located outside the European Union and we may engage partners outside the European Union who will also process and store your information to provide services to us. 9. Links to third party websites and services We may provide links to third party applications, services or websites from our Services (including advertising that may link to a third party). You understand that when you click on these links any data which you provide afterwards is subject to that third party's privacy policy and not to ours. We can take no responsibility for the content, safety, privacy or security of any third party application, service or website. 10. Changes to the policy The privacy policy and this summary may change over time. We will post the updated privacy policy on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us. 11. Contact us If you want to contact us about any of the matters in relation to this privacy policy, including to exercise any of your rights, then please contact our customer services department by emailing [email protected].