Privacy policy - last updated February 14, 2023

Welcome to FUN-GI where we understand the importance of your private information. A lot of personal information floats around even as you play games, and we understand there’s a lot of responsibility in handling that information which is why we have a policy that explains how we collect, store, use, and manage the information you provide or we collect in connection with our websites, including www.fun-gi.com, or any FUN-GI game provided on another platform (such as the iOS App Store or Android Google Play Store). Also, there is a new law called the General Data Protection Regulation (or ‘GDPR’) in effect starting May 25, 2018 that places new obligations on organizations that process personal data in the European Union (EU), and we’re taking the initiative to share what we’re doing to look out for your privacy. Additionally, there is a law called the California Consumer Privacy Act (or ‘CCPA’) in effect starting January 1, 2020 that applies only to individuals who reside in California and 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.

Transparency of data

We collect a range of data from players and send it to third parties in order to give the best game experience possible. Here we give a high level outline of the types of companies we send data to and why:

• If you make a purchase of any good or service through the Services, including any Virtual Currency or Virtual Good, our payment processing service provider (such as Apple’s App Store and Google’s Play Store) will collect your name, phone number, e-mail address, mailing address, billing address, and 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.
• If you login to social networks or choose to share from our games, we send data to these social networks to enable the social activities in the game. For example, so that you can see what your friends are doing in the game, take part in the leaderboards, send and receive gifts, and post on social media.
• We send data to marketplaces where they handle the processing of physical commerce and e-commerce. For example, a brand you see in-game may have a corresponding product which you may wish to purchase in real life.
• We send data to companies who provide analytics services to improve the whole game experience for you. From things like enabling us to tell which levels might be too difficult so we can adjust them, to improving our special game events and in-game sales for you.
• We send data to crash reporting service companies so that we know when there are bugs or crashes in the game, so that we can fix them.
• We send data to our own database in order to save your game progress through the levels.
• We send data to customer service software companies so that you are able to contact the Community team at FUN-GI, and visit the FAQ if you have any questions.
• We send data to store-based achievement centers (Game Center for iOS and Google Play services for Android) to give the Achievements and Leaderboards that you get for playing the game and also so that we can learn about how you play the game to make it an even better experience.
• We send data to ad networks in order to show you advertisements in the game.
• We send data to attribution tracking companies so that we can know from where you learned about the game (i.e. we can tell if you came to the game through one of our advertisements or if you just found us on the store).
• If you decide to sign-up for our newsletter, we send data to newsletter agencies in order to send you our latest newsletters.
• If you sign up to push notifications, we send data to push notification service companies in order to send you push notifications on your device reminding you about things in the game (for example if your energy is full, or if there is a special event on).
• In games where Chat is available, we send data to chat system management companies in order to filter profanities and keep the chat a safe and fun place to be.

Under no circumstances do we sell your personal information to any external companies. All of our data collection is done to improve our players’ experiences and to make better games.

If you have any questions relating to your data privacy and FUN-GI, please contact us at [email protected].

Under GDPR, if you are in the EU, you have the right to request details of the specific data we collect and how we use it. As an EU citizen, you also have the right to request that your data is erased. To do this, please contact us via [email protected].

What personal information does FUN-GI collect and why?

FUN-GI is a game development studio with offices in Los Angeles, CA, United States.

For more information about FUN-GI, please see the Company section of our Website at https://www.fun-gi.com/about.

The personal information that we may collect about you through the Services broadly falls into the following categories:

• Information That You Provide Voluntarily Certain parts of our Services may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to begin playing Games, to subscribe to marketing communications from us, and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
• Information That We Collect Automatically When you use our Services, we may collect certain information automatically from your device. This information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically includes information like your IP address, device type, unique device identification numbers, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Services, including the games played and the pages of our Website accessed. Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
• Information That We Obtain from Third Party Sources From time to time, we may receive personal information about you from third party sources (including Facebook), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.The types of information we collect from third parties include your name and friend list, and we use the information we receive from these third parties to provide features like in-game friends, in-game gifts, and competitive leaderboards.

Who does FUN-GI share my personal information with?

We may disclose your personal information to the following categories of recipients:

To our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. A full list of our current partners in the EU is:

• Apple

  Apple Store is used to provide you the Games as well as to provide in-app purchases; Game Center provides Achievements in the Games.

  https://www.apple.com/legal/privacy/en-ww

• Google

  Google is a Google Play store provider which enables in-app purchases. Google Play Services allows us to provide achievements and leaderboards.

  https://policies.google.com/privacy

• Google Cloud

  Google Cloud and G-suite are used to store information about progress and analytics.

  https://cloud.google.com/security/privacy

• HelpShift

  Helpshift provides customer service software to help us respond to your requests.

  https://www.helpshift.com/legal/privacy

• AdColony

  Ad network serving contextual ads.

  https://www.adcolony.com/privacy-policy

• Unity Technologies

  Platform that provides us with an engine which we use to build the Games; provides us with analytics tool.

  https://unity3d.com/legal/privacy-policy

• Facebook or Meta

  Provides us with friends names who also play our games and is optional.

  https://www.facebook.com/full_data_use_policy

• Facebook or Meta Audience Network

  Ad network serving contextual ads.

  https://www.facebook.com/about/privacy

• Singular

  Singular is an attribution platform that helps identify where our players discover our Games.

  https://www.singular.net/privacy-policy/

• Crashlytics

  Crashlytics is a crash reporting tool that helps us diagnose where bugs are occurring so that we may fix them.

  https://firebase.google.com/terms

• AdMob

  Ad network servicing contextual ads.

  https://support.google.com/admob/answer/6128543?hl=en&ref_topic=9756841

• Vungle

  Ad network servicing contextual ads.

  https://vungle.com/privacy/

• Frameplay

  Ad network servicing contextual ads.

  https://www.frameplay.gg/terms

• Fyber

  Ad network serving contextual ads.

  https://www.digitalturbine.com/privacy-policy/

• Amazon

  Amazon is an e-commerce and mobile app distribution platform.

  https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ

• Walmart

  Walmart is an e-commerce and mobile app distribution platform.

  https://corporate.walmart.com/privacy-security/walmart-privacy-notice

• Game Analytics

  Business intelligence and data visualization tool to help us understand the health of our game.

  https://gameanalytics.com/privacy

• To a competent law enforcement body, regulatory, government agency, court or other third party where the disclosure is required and necessary (i) as a matter of mandatory applicable law or regulation and/or valid court order, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• To a potential or actual buyer (and its agents and advisers) in connection with any proposed or actual purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• To other players and users where social features are a core component of our games. Other players and users may, for example, see your player profile data, in-game activities, and read the messages you have posted.
• To any other person with your consent to the disclosure.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

We will process your information for the purposes of operating our Website, Games and other Services and communicating with you as necessary for those purposes and in our legitimate commercial interests, for instance, when responding to your queries, undertaking marketing activities, improving our Games, Website and other Services, or for the purposes of detecting or preventing illegal activities.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us via email [email protected].

How does FUN-GI keep my personal information secure?

We use appropriate technical and organizational measures designed to protect the personal information that we collect and process about you. We have voluntarily established and continue to maintain an information security program that follows the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF). The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use are, for example, encrypting your personal information in transit and at rest, only collecting vital data, as well as ensuring access to the data is restricted internally and externally. 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.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country.

Specifically, our servers are located in United States, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. All third parties that are located outside of EEA are certified under “Privacy Shield” (framework for EU-USA data transfer) or employ European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your data protection rights

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
• In addition, in certain cases, you can object to processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
• Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance of lawful processing grounds other than consent.
• You may also limit data collection by third parties by using your mobile device privacy settings of your Android or iOS device and turning off “Allow Apps to Request to Track” or selecting “Limit Ad Tracking” (Apple iOS) or “Opt-out of Interest Based Ads” (Android). 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 note 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.
• You have the 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.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Policy regarding children

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use our games. If you are under 13, 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 13 may provide any personal information. We do not advertise or otherwise direct our games to individuals under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible.

Under GDPR, if you are in the EU and under the age of 16, in order for you to use our games you must receive consent or authorization from someone who holds parental responsibility for you. We will make reasonable efforts to verify in such cases that consent is given or authorized by the holder of parental responsibility.

Provisions for California Consumers

Additional provisions for California consumers apply only to those individuals who reside in California.

• Categories of personal information collected in the preceding 12 months: see ‘Transparency of data’ section above.
• Business purpose for collection: see ‘What personal information does FUN-GI collect and why?’ section above.
• Third parties with whom we may share your information: see ‘Who does FUN-GI share my personal information with?’ section above.

As a resident of California, you have the 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.” Please note that 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.

CCPA also gives you the 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. At FUN-GI, 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 30 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

Updates to this privacy policy

We may update this privacy policy from time to time in response to changing legal, technical, or business developments. When we update our privacy policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material privacy policy changes if and where this is required by applicable data protection laws.

You can see when this privacy policy was last updated by checking the “last updated” date displayed at the top of this privacy policy.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following email address: [email protected]

If you want to exercise your rights in relation to personal data that we have collected, please contact us through the Game by going to Options -> Help -> Contact Us, or, if you are unable to contact us through the Game, by using the following email address: [email protected]. Contacting us through the game is the preferred method of contact as it will enable us to more accurately validate your request.