Privacy Policy

Last Update: November 19, 2023

1. INTRODUCTION

1.1. This Privacy Policy (“ Policy ”) explains the ways in which FreakPlanetStudios (referred to as “FreakPlanet”, “we”, “us” or “our” in this Policy) 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. In this Policy, » Services » means our Games, Websites and any related services or properties that we directly control. “ Games ” means online games or applications that we own and operate. Please review our List of Games governed by this Policy.

1.3. BY INSTALLING, USING, REGISTERING OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE EXPRESS 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, DO NOT INSTALL, USE, REGISTER OR OTHERWISE ACCESS THE SERVICES.

1.4. FreakPlanet reserves the right to modify and update this Privacy Policy from time to time, so be sure to check this page from time to time to review this Policy. Changes to this Privacy Policy will be effective immediately after such changes are uploaded to our websites. Your continued use of the Services will signify your acceptance of the changes to this Privacy Policy.

2. RESPONSIBLE FOR THE TREATMENT

By «controller» we mean an entity that determines how and why personal data is processed. We will retain your personal data in accordance with applicable data protection laws. For the purposes of data protection laws, the data controller will be FreakPlanetStudios.

While we operate 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. For more information about these partners and the ways in which they may process your data, please see section 6 of this Policy.

3. WHAT DATA WE PROCESS

3.1. When you access our products and Services, we will not collect your legally sensitive data (i.e. race, ethnicity, religious or philosophical beliefs, union membership, genetics, biometrics, health, sexuality and/or criminality) or other sensitive data (i.e. , child information, social security numbers, bank account or payment card details). Please do not provide us with this type of information or use the Services to make it available to others.

3.2. We may collect user data from you, including:

– your name, email address or other contact information if you have provided it 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 that 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 approximate location (e.g. country, state or city), deduced 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 advertisements in our Games),

– information about your interactions with our ads outside of the Services (for example, on third-party websites or applications), including information about how you were referred to our Games or other Services,

– crash logs or other information related to crashes, errors or other problems in our Services,

– inferences we make based on your activity on our Services,

– messages or other communications that you send to us or through the Services (for example, your chat messages in our Games or emails that you send to our support team),

– if you choose to connect a third-party account (for example, a social media account) with our Services, the information we receive from the third-party account provider (for example, an account name, identifier or email address to enable cross-connect) – play the device or a profile name, image or friends information to provide social functions),

– if you make purchases on 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 that you provide to us in doing so (for example, information about your background or experience with our Games),

– any other information you choose to send to us through our Services or otherwise, and

– with your consent, other information that has been explained to you when requesting your consent.

3.3. Cookies.- Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites you visit and stored in your device’s internal memory.

This Service does not use these «cookies» explicitly. However, the application may use third-party code and libraries that use

«cookies» to collect information and improve their services. You have the option to accept or reject these cookies and know when it is sent

a cookie to your device. If you choose to reject our cookies, you may not be able to use some parts of this Service.

4. HOW WE COLLECT YOUR DATA

We may collect and receive information that may be considered personal data under applicable laws in a variety of ways. More specifically:

– directly from you when you send it to us (for example, by registering an account with us, subscribing to our communications, sending us support queries or responding to our surveys),

– directly from you and/or your device by automated 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 development kits software (SDK),

– from our advertising partners involved in the delivery and measurement of ads when you interact with third-party ads in our Games or ads from a specific company (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 on our Services, to the third-party payment service provider involved in those transactions, or

– with your consent, from other sources that were explained to you when requesting your consent.

Providing us with data is not mandatory. However, we cannot provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data related to you for some or all of the purposes described in this Policy, depending on the Services you choose to use and your choices in using them.

You have several options to limit or control the extent to which your data is processed. For example, you can choose not to connect your third-party accounts with our Games, use your device settings to reset or limit the use of your advertising ID, deny consent to personalized advertising, or disable some or all cookies from settings. from your browser.

5. WHY DO WE COLLECT YOUR DATA?

5.1 General:

When we process or collect your data, we make sure we have a legal basis for doing 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 setting up, managing and administering your betting account (including for anti-money laundering, prevention terrorism financing, processing self-exclusion requests and identity verification purposes) and to place, settle and pay bets;

– to notify you about changes to the products and services we offer and (where you have indicated your consent) to market these products and services directly to you;

– to administer our websites for internal operations, including troubleshooting, data analysis, testing, research, statistics and surveys;

– to enable 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;

– 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 on the Service;

– Improve customer service;

– provide features available on the Service;

– audit and analyze the Service;

– guarantee the technical functionality and security of the Service;

– to inform you about promotions, rewards, upcoming events and other news about products and services offered by us;

– to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and administrative and support messages;

– for statistical and research purposes (including market research, marketing and data analysis purposes);

– identify your betting behaviour, habits and preferences;

– analyze your credit risk (if applicable);

– manage payment and collection processes to and from clients;

– to ensure the effective functioning of the software and IT services we acquire (including disaster recovery);

– for the purposes of anti-money laundering, prevention of terrorist financing and identity verification; and

– to comply with regulatory and licensing requirements applicable to us; and

– for other reasons with your consent.

5.2 Marketing:

Marketing refers to advertising, one of the tools that helps finance our Services and allows us to offer our Games for free. In some of our Games, we may display our own ads as well as third-party ads. We also advertise our Games outside of our Services on third-party properties, such as websites or applications. This section provides more information about how we may use your data for advertising purposes and how you can control the use of your data for these purposes.

Mobile advertising is based 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 (for example, your phone or tablet). It is consistent between applications from different editors. The Advertising ID is known as Identifier for Advertisers (“IDFA”) on iOS devices and as 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. By using your device’s privacy settings, you can usually 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 device-specific, meaning you must configure them as you prefer on each of your devices individually. It may take some time for the updated settings to take effect.

Please note that resetting or limiting the use of your advertising ID will not prevent 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 consented to our 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 various purposes, including limiting the number of times you see an ad or personalizing the ads you see to make them more relevant to you (for example, based on previous activity they have performed). associated with your advertising ID). For more information, please review 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 apps), the ad network involved in delivering that ad to you may, based on information such as past activity that they have associated. With your advertising ID, we have determined that you may be interested in our Services. When advertising networks use your advertising ID in this way, they do so in accordance with their respective privacy policies or notices.

Advertising 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 advertised Game.

3) Both for ads in our Games and for our ads outside of our Services, advertising IDs or other identifiers are also used for ad measurement, which involves collecting metrics such as total views, clicks or installs generated by an ad. Measurement data may be collected or received directly or indirectly by multiple parties involved in the delivery of ads (including us and our advertising partners), for example, through technologies such as web beacons embedded in ads. This data is used for purposes such as providing measurement services, detecting, investigating and preventing fraud or fraudulent behavior, or settling payments between parties involved in delivering ads.

6. WHO WE SHARE YOUR DATA WITH

We may share your data with third parties to achieve the purposes described in this Policy. This may include sharing data with the following types of recipients:

6.1. Related entities

We will use your personal data and disclose it to our group companies, including FreakPlanetStudios and all of its subsidiaries.

6.2. Selected business partners and advertising partners

Your personal data will be disclosed by us to our partners we work with in the course of providing the Services (who may process your data independently of us), including advertising partners, intellectual property licensors and others listed here.

6.3. Public authorities/regulatory bodies/industrial bodies

We may disclose your personal data: to regulators and law enforcement agencies (including those responsible for enforcing anti-money laundering legislation); or in response to an inquiry from a government agency.

6.4. Service providers

We may disclose your personal data to third party service providers (including our professional advisors, data analytics processors and data storage service providers) who require access to such information in order to provide specific services to us. These third parties will generally only be able to access your data to provide us with their services and will not be able to use it for their own purposes.

Amazon’s AWS will record your personal data and in-game behaviors in the US.

6.5. Replacement Suppliers

If the management and operation of FreakPlanet and its affiliates is transferred from us to another company, we may disclose your personal data to the other company so that the products and services can continue to be provided to you.

In the event that we sell or buy business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.

If FreakPlanet or substantially all of its assets are acquired by a third party, personal data we hold about our customers will be one of the transferred assets.

7. HOW LONG DO WE KEEP YOUR DATA?

We will retain your data for as long as necessary to achieve the purposes for which it was collected, including to provide you with the Services or to satisfy any legal, accounting or reporting requirements. We may periodically delete or de-identify inactive accounts or other data in our Games or other Services. After the applicable retention period necessary for the secure provision of the Services, we will delete or de-identify your data or, if neither deletion nor de-identification is possible (for example, because the data is stored on a backup server), we will isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregated data).

8. HOW DO WE KEEP YOUR DATA SECURE?

We take the security of your personal data very seriously. We implement appropriate technical and physical security measures to ensure that your Personal Data is protected against loss, destruction, alteration, unauthorized access or disclosure or any other unlawful use or processing of the Personal Data you have provided to us. Our security mechanisms for Personal Data are similar to those of other game developers. However, please note that the Internet is not 100% secure and any access, disclosure, alteration or destruction of personal data you have provided through our games cannot be guaranteed due to failure to comply with our security measures.

9. YOUR RIGHTS

You have several rights in relation to the data we hold about you. We have exposed them below.

To contact us about any of these rights, please find the contact details described in Section 14 below. We will try to accommodate your request without undue delay. Please note that we may keep a record of your communications to help us resolve any issues you raise.

9.1. Right to access your Personal Data.

You have the right to know what Personal Data we have 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, for us to communicate the information to you. If you wish to exercise your right of access, please contact us as described below and let us know what particular information you would like to receive. We reserve the right to request reasonable evidence to verify your identity before providing you with any information. Please note that we may not be able to provide you with all the information you request, for example, if the information includes personal information about another person. Where we are unable to provide you with the information you have requested, we will endeavor to explain why.

9.2. Right to correct or update your Personal Data.

You have the right to request an update or correction of any of your Personal Data that is out of date, incomplete or incorrect.

9.3. Right to delete your Personal Data.

In certain specific circumstances, you have the right to ask us to delete the personal data we hold about you. We will pass your request on to other recipients of your personal information unless it is impossible or involves disproportionate effort. If you would like to ask us for more information about the specific circumstances and who the other recipients are, and/or exercise your right of deletion, please contact us. Please note that some things can only be deleted when you delete our games from your mobile devices and delete our cookies from any devices 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. When 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 the integrity of our database. . We may also retain your information anonymously. In some cases, personal information about you that is visible during 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 delete them. or update that data from those devices. for example, if that device is not connected to a network. You can ask us for more information about the specific circumstances and who the other recipients are, using the contact details described in Section 14 below.

9.4. Right to limit the processing of your personal data.

In certain specific circumstances, you have the right to object to the processing of your personal data that is processed on the grounds of legitimate interests. You can ask us for more information about the specific circumstances using the contact details described in Section 12 below.

9.5. Right to object at any time to the processing of your personal data where the 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. that require protection of personal data, particularly when the interested party is a child.

9.6. Right to opt out of direct or interest-specific advertising in mobile applications by checking the privacy settings in the settings menu of your device. Please note that even if you use your opt-out right, you will still receive advertising, but not direct or specific interests. On Apple, you can turn this off by going to Settings Privacy Advertising and turning on «Limit Ad Tracking.» On Android, you can opt out by going to Settings Google Services Ads and turning on “Opt out of ad personalization.”

9.7. Right to the portability of your personal data. In some circumstances, you may have the right to request that the data you have provided to us be provided to you, so that you can transfer it to another controller.

9.8. Right to withdraw your consent at any time if we are processing your personal data with your consent.

9.9. Right to lodge a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

9.10. In some cases, our use of your Personal Data may result in automated decision-making (including profiling). Automated decisions mean that a decision that concerns you is made automatically based on a computer determination (using software algorithms), without our human review. For example, we use automated decision-making to provide direct or targeted interest-based advertising on our Services. You may opt out of receiving direct or targeted interest-based advertising by following the instructions in Section 9.6. above.

9.11.Right to Opt Out (California, USA): California residents have the right to opt out of the sale of personal data, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. If you opt out of the «sale» of your data, we will not sell it, including to our advertising partners, but you may still see ads in the game and some of our partners may show you ads, depending on what information you expect.

The EU General Data Protection Regulation (“ GDPR ”) grants you the above rights in relation to your personal data. Although we will not normally do so, we reserve the right to charge you an appropriate fee for the exercise of your rights where permitted by applicable laws and regulations. If you believe that we have violated your privacy rights, please contact us so we can try to resolve the issue. If you are an EU resident, you have the right to lodge a complaint with your local supervisory authority.

10. INTERNATIONAL TRANSFER

Our Service is global in nature and therefore your data may be transferred to any part of the world. Because different countries may have different data protection laws than your own country, we take steps to ensure that adequate safeguards are in place to protect your data as explained in this Policy. These include the implementation of the European Commission’s Standard Contractual Clauses for transfers of personal data between our group companies and third-party partners and service providers, which require all group companies to protect personal data they process from the EEA. in accordance with European Union data protection law. It also includes the transfer of personal data to partners and third-party service providers who are certified under the EU-US Privacy Shield. and Switzerland-U.S.

11. DELETION OF USER DATA

The user 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, they can delete or delete it.

Range of data that can be deleted: 1) The basic information of the user’s Facebook account obtained by the application; 2) User account login registration; 3) All user operation records in the application, such as level records, purchase records, etc.

There are notes that users should keep in mind before deleting or deleting users. Depending on the users account, deleting or deleting users may have the following effects: 1) The application will delete all user data; 2) Before deleting 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) Once user data is deleted, it cannot be recovered.

Steps to delete data in the app: 1) Go to your Facebook profile and find the Apps Websites page in Facebook Settings; 2) Delete our application; 3) Click the Deleted sub-tab, search for our app and submit a data deletion request.

12. CHILDREN POLICY

This Service is not directed to children under thirteen (13) years of age. By agreeing to our Terms of Service and using our Services, you represent that you are at least 13 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 13 nor do we knowingly allow such persons to use our Services. If you are under 13 years of age, please do not use the Service or send us any information about yourself.

13. CHANGES

We may update this Policy from time to time, for example due to changes in our operations or legal obligations that apply to us. Updates will be available here. Therefore, we encourage you to consult this page periodically. We may also notify you of any changes by other means that are appropriate to the significance of the changes.

14. CONTACT US

If you have any questions or concerns about this Privacy Policy or any other issues with your personal information while using our Services, please feel free to contact the Game You Play support team via the email address listed here (freakplanetstudios@gmail.com).