OUR APPROACH TO PRIVACY

Spunge Games and all its related entities considers your privacy to be very important. As an Australian company we strictly comply with Australian privacy laws and GDPR.

This Policy outlines the types of personally identifiable information and other data that we will collect from you through the various websites, games and applications we provide (“Products and Services”), and how we might use or disclose such information and data to third parties.

By using any Spunge Games Services you agree to the collection and use of your personal information in accordance with this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not provide us with any information and do not use the Services.

COLLECTION OF INFORMATION

We may collect two types of information through your use of our products and services.

• “Personal Information” information that can specifically be linked to you personally, such as your full name, physical address, email address, telephone number, photograph, location, credit card information and user names – Spunge Games does not store this information unless it has been provided for the express purpose of being included on our marketing mailing lists.
• Non-personal “Usage Data” anonymous data about how you use and or interact with our products and services that is tied to your computer or device through which you use our products and services – all data collected directly via our mobile games falls into this category.

We receive and store any information you give to us, when you: download our games; enter our competitions; are involved in our special events (e.g. focus testing days); interact with our social media such as Facebook and Twitter; enter information on our Website; purchase our merchandise; subscribe to our newsletters or other information feeds; make an in-app purchase; request technical support, make a compliment or complaint, or otherwise contact us or give us your information in another way.

We also receive and store certain types of information when you interact with our products or services including:

• information about how you use our Products and Services. We use this information to continually improve our products and their features as well as our services. When you sign-in to our games over social media, we use the information from that provider so that you can enjoy the same game on multiple devices, pick up where you left-off, and interact with your friends.
• information about the device you use to access out products and services such as its model, operating system, screen resolution, web browser, IP address, Media Access Control (MAC) address, Advertising Identifier, Language and other technical information such as cookies and randomly generated unique identifiers.
• your location so we know what language to use and so that we can provide the relevant games/features/promotions/advertisements that are applicable to your location; and
• if you “tell a friend,” “email this page,” or use other similar features, we will collect information to perform this feature for you.

THIRD PARTIES

Please note that your access to and use of our Products and Services may be subject to certain third-party terms and conditions and we are not liable for any such third parties’ use of your personal data. Certain Products and Services may use third party services to provide authentication with a gaming console ID, social networking ID, or gaming network account. In connection with such use, certain personally identifiable user and/or membership data may be transferred automatically to and from us. Sometimes we collect information about you from third parties, such as Apple, Facebook, or Google, Inc. We collect this information so that we can deliver services to you that you have requested. We collect this information:

• when you purchase our Products and Services via the App Store, or Google Play Store, or another storefront.
• if you log into our Products or Services via a social media account (such as Facebook or when you use in-app features such as Game Centre).

USAGE OF INFORMATION

We will use your Personal Information to provide you with any goods, services, or functionality you have requested or respond to any inquiries you have made. We may also use your Personal Information in order to contact you to promote our websites/apps, contests and any specials we may offer. In the event that we send you advertising or marketing materials, we will provide you with the opportunity to opt-out of receiving such materials in the future. You may also opt-out of receiving such materials at any time in accordance with the instructions provided in this Privacy Policy.

Usage Data may be used by us for administrative, analytical, research, optimization, security and other purposes. Specifically, we may use your Usage Data to help us learn more about your gaming activities, personalize your content, compile statistics, respond to customer service inquiries, provide security and to otherwise enhance your gaming experience.

Usage Data may also be used to help us provide you advertising that better suits your interests. Geolocation information will be used to determine the jurisdiction in which you are located so we can determine what set of laws apply to you. Your device ID may be used so we can send you push notifications (if you choose to allow that function) and track your use of our Websites/Apps so that we can better understand your preferences and tendencies which will help us best personalize your experience and provide you with in-game offers and notifications that are tailored to you.

We may provide aggregated or anonymous information to third parties for the purposes of developing and delivering targeted advertising. We will not provide your personal information to advertisers.

We may use information held about you to verify your compliance with our Terms of Service.

Service security maintenance

• Monitoring of Service usage
• Detection of suspicious activity
• Taking action against fraudulent players

Ads personalization

• Improvement of the advertisements presented to you in accordance with your online behaviour
• Analysis of the advertisements effectiveness & their according tailoring

Please note that Spunge Games, in particular, uses the services provided by Smaato and their vendors. Smaato is an advertising service provided by Smaato, Inc. (US). You can access Smaato’s privacy policy at https://www.smaato.com/privacy/ . For more information on the Smaato Vendors, please visit: https://advertisingconsent.eu/vendor-list/ 

WHEN DO WE DISCLOSE INFORMATION?

We may disclose the personal information we hold about you in the following circumstances:

• If we are required or authorised to disclose by law or by a law enforcement agency.
• To our business partners in the course of providing our Products and Services to you, or generally in the conduct of our business. This may include organisations who provide services to us, such as payment processors or hosting services.
• To avoid, lessen or prevent a serious emergency or crime. If we use or disclose personal information about you in those circumstances, we will make a written record of such use or disclosure.

CHILDRENS’ PRIVACY

While our Products and Services may be played and/or visited by children, we do not knowingly collect or use any Personal Information from children under the age of 13 and hereby specifically prohibit any user under the age of 13 from providing us with any Personal Information. If you are a parent of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at [email protected] and we will delete the information from our system.

We may collect a device ID or other persistent identifier linked to the device or computer that may be used by a child to play our Products and Services. The data collected will be anonymous and not tied to any Personal Information.

If you permit your child to use one of our Products and Services, you should disable in app purchases on your phone or device and actively monitor your child’s use.

DIRECT MARKETING

We may use your information to tell you about our Products and Services and share news about us and our new games we are launching, events we are running, or merchandise we sell. You can always opt-out if you do not want to receive this news or information.

IN-APP PURCHASE

Some of our products and Services offer in-app purchases or items or additional features you can purchase (for real or in-game currency). If you do not want to make in-app purchases, do not use these options and consider disabling them on your device.

OPTING-OUT

Ways to opt-out of our Services:

• via email, there will be an unsubscribe link
• via Facebook you can ‘unlike’ our page
• via Twitter you can stop following us

For assistance with opting out please contact us at [email protected]

REQUESTS FOR DATA DELETION OF PERSONAL INFORMATION:

You have the right to request & obtain deletion of your personal information collected through our Services.

If you would like to exercise the right, please send your request at [email protected] (please note that if your request is sent to any other Spunge Games email, we are unable to guarantee its receipt & further processing). We will aim to respond to your request within 30 days from the initial receipt of the request. In order to realize your right, we need to identify you as the original account owner. You acknowledge and agree that this purpose we shall request additional personal information from you, such as photos and copies of your documents that you will need to provide. Provision of these documents is obligatory to avoid fraud and make sure your account is secure from possible damage.

Please note that deletion of your personal data will be followed by deletion of the related information, such as your in-game progress, including your level, purchased content licenses (including real money purchases) and any in-game content associated with the account. The restoration will be impossible. By requesting to delete your personal data, you acknowledge and accept this fact and approve the deletion of this related information.

Please note, that in case your consent to processing is withdrawn by you, you may still not be able to access Spunge Games Services anymore.

Please keep in mind that all correspondence regarding the personal data deletion can only be held in English.

THIRD PARTY SERVICES

When you use Spunge Games services, you might also use third party services such as Facebook, Twitter and Game Centre. We cannot control how they interact with you and you should ensure that you consent to the terms of use and privacy policies offered by these third-party services before providing them with your information.

By using our services, you acknowledge that we are not liable when third party services use information you provide to them.

We also work with certain business partners, such as other game developers and advertising partners, and information collected from you may be shared through these partnerships.

Some of our business partners are outside Australia. Below is a list of some, but not all, business partners that we actively share user information and site usage data with (this list is subject to change):

• Apple (Search Ads) https://support.apple.com/en-us/HT202074
• AppLovin https://www.applovin.com/optout
• Apps Flyer https://www.appsflyer.com/privacy-policy/
• AdColony https://www.adcolony.com/privacy-policy/
• Chartboost https://chartboost.zendesk.com/hc/en-us/articles/200780269-Privacy-Policy
• Facebook https://www.facebook.com/help/325807937506242
• Firebase https://firebase.google.com/support/privacy/
• Fyber https://www.fyber.com/privacy-policy/
• Google (Adx) https://www.google.com/ads/preferences/html/mobile-about.html;
• Google (Ad Words) https://support.google.com/ads/answer/2662922?hl=en;
• Google (AdMob) https://www.google.com/ads/preferences/html/mobile-about.html;
• Instagram https://help.instagram.com/155833707900388
• Ironsource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
• Smaato and its partners https://www.smaato.com/privacy/ https://www.smaato.com/partner-list/
• TapJoy https://dev.tapjoy.com/faq/tapjoy-privacy-policy/
• Unity https://unity3d.com/legal/privacy-policy
• Vungle https://vungle.com/opt-out/

ADVERTISING ID

Understanding our players is fundamental to creating a fun game that our fans want to play. An advertising ID is a unique ID which gives users better controls and provides developers with a simple, standard system to continue to monetize their apps and ensure customers and given advertising for products and services which match their interests. You can reset your ID at any time via the settings on your mobile device. Collecting your advertising ID helps us understand what your interests are and how we can tailor your experience to match.

STORAGE & SECURITY

We follow generally accepted industry standards and maintain reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in our possession.

ACCESS & CORRECTION

You may request access to your personal information at any time by sending a written request to our Privacy Officer at
[email protected]

We may charge a small fee for providing access if it requires a significant amount of time to locate your information or to collect or present it in an appropriate form. We may decline your access if there are reasonable grounds to do so. If your information changes, let us know so that we can update our records. If you would like us to de-activate your records that we hold, please tell us. Once de-activated your data will not be accessible. However, due to system backups to various types of data storage media, your data may in some circumstances remain on these types of data storage media. There may be circumstances where we decline to de-activate your records.

COMPLAINTS CONTACTS

If you have any concerns or complaints about your privacy please contact us by:
Sending a written request to our Privacy Officer by mail at:
[email protected]

We will respond to your complaint within a reasonable time after we receive it, provided you supply return contact details.

UPDATES TO THIS POLICY

We will update this Privacy Policy from time to time. These updates, will take effect from the date of issue on our website at www.spungegames.com. Please check back regularly for updates.

DEFINITIONS

• Spunge Games (“us”) – its assignees, licensees, successors in title and subsidiaries.
• Products and Services – Products and Services offered by us and includes our games, websites and related services.
• Game Centre – A central game hub that retains information regarding game play statistics that is openly shared with the user. This includes high scores, global leader boards, friend’s lists, and in-game achievements.
• Storefront – An online business presence for sales. We work with the Apple App Store and Google Play storefronts as their primary storefront for sales, but our games are also available on Amazon App Store and Windows Phone Store, among others.
• Analytics – Interpretation and interpolation of unidentified data to predict and isolate trends relating to game play and app use.
• In-app purchase – An in-game system that allows exchanging real money for virtual goods or in-game currency.
• Third party services – Services provided by a provider that is not owned or controlled by us.