We promote our Apps and services in ours and other publisher’s apps and we also allow our partners to promote and advertise their goods and services in our Apps. We may share information we collect from you to our advertising partners and they can reuse such data for targeted advertising. We or our advertising partners may display interest-based, or retargeted, ads (”IBA”), but only for the device IDs that have passed the age gate and have not opted out of IBA. By using our Apps and not choosing one of the opt-out options, you give us consent to transfer your data as stated below.
a) Via third party IBA provider:
If you choose to opt out by following one of the third party IBA provider’s opt out mechanism, you should stop receiving interest-based and targeted ads via the selected IBA provider, but you may continue to receive interest-based or targeted ads through other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options b) and c) below.
b) Via “Do Not Track Settings” in mobile phone:
Turn on “Limit Ad Tracking” on your iOS device or “Opt Out of Interest-Based Ads” on your Android device.
c) Via our Apps:
Choose “Opt Out of IBA” within the settings of our Apps (where available).
INFORMATION AND DATA WE COLLECT FROM YOU
1. Technical Information And Data
We collect technical data necessary for you to use our App and additional technical data that enables us to maintain and analyze the functioning of the App, to personalize the content of the App, and to display advertisements.
We automatically obtain certain information about your computing device, including:
- IP address; Country code;
- IDFAs, IDFVs, Advertising IDs;
- Language; Locale (specific location where a given language is spoken);
- Time zone, session start/stop time,
- Network status (WiFi, etc.), browser plug-in types and versions;
- User agent string (UA), platform, SDK version, timestamp;
- All apps installed;
- Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, International Mobile Equipment Identity (IMEI) on Android, Android ID, Android Serial No);
- Push notifications token;
- Player identifier string (we collect player identifier string only upon your sign in to Google Play Games Services or Apple’s Game Center).
In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Apps.
Older versions of our Apps may still obtain information such as UDID number and IMEI number on iOS. If you wish to prevent this, please update the App with the latest version available on App Store.
2. Advertising And Application Usage Information And Data
When you use our Apps, we may collect additional information by using device identifiers that permit identification of your device. Such information is used for advertising and analytics purposes.
The information collected includes:
- Which advertisements are shown;
- Length of time an advertisement is visible and the size of the advertisement;
- Advertisement response (if any), including clicks on ads;
- Angle of view;
- Application usage information, (how often you use the app, for how long you use the app, the events that occur within the app, in-app location, in-app purchases you make and their value, aggregated usage, performance data, life time value of user etc.).
3. Classical Personal Information
We do not collect any personal information about you through our Apps, with the sole exception of persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address). Persistent identifiers are identifiers that do not identify you personally, but may uniquely identify your device. Some legislation (such as US) may treat such information that uniquely identifies your device as personal information.
When you voluntarily contact us directly, we may collect information about you that you provide us (such as your name and surname, email address). We will use such contact information only for the purpose for which you provided it to us. We will not share this information with third parties.
If you wish to delete your contact information that we received from you when you contacted us, please send an e-mail to email@example.com and your contact information will be deleted from our database.
HOW WE USE YOUR INFORMATION
1. In General
We use the information we collect about you/your device to deliver services to you and to operate our business. Such use by us and by our Partners may include:
- Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analyzing trends in connection with usage of the Apps, administering the Apps, and customer communications.
- Cross-promotion: cross promoting our Apps and services, meaning we may promote one of our Apps while you are playing a different App of ours.
2. Push Notifications
We use push notifications to remind you about your activities within the App. You will receive push notifications only if you are subscribed to push notifications in the App. To unsubscribe, please use the instructions provided below:
- For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap “Notifications”; Find the App; Tap on the icon of App; Manage the “Notifications” option by sliding it OFF or ON.
- For Android and Windows: After an App is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the App and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the App.
We collect push notification tokens in order for us to be able to determine whether you are subscribed to push notifications. When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.
We are conducting surveys in order to improve our services and you may freely decide whether you would like to help us or not.
From time to time we may conduct an in-app survey and collect demographic and usage information for the purposes of internal analysis, marketing and brand development. Participating in a survey is completely voluntary. We will use the information to make our services more appealing to users. Collected information shall be anonymized and aggregated. We might collect the following information: age and gender of the user of an app, whether another person uses the app, the age and gender of the people regularly using the app, assessment of popularity of the main character, which of the characters are known to the user, which app is most commonly used, whether children under the age of 13 use the app on their own or with an adult, the gender of users playing the app, different ways of using the app, an assessment of the features of an app, the time period of using the app, which apps the user has, what would make the app more appealing, and other information needed for the purposes of internal analysis, marketing and brand development.
We may use third party providers for the in-app surveys and they may place their tags within an App to collect non-personally identifiable data from the device (”Tag Data”) solely for the purposes of conducting the survey, such as to collect cross device information in order to enable the deduplication of audiences across devices. These providers may use the data collected from the survey and Tag Data on anonymized and aggregated basis together with the data from other partners (”Unified Data”) to publish syndicated reports on internet behavior and trends. If you wish to opt out from conducting an in-app survey, do not click on the survey button or deny answering the survey questions.
HOW WE MAY SHARE YOUR INFORMATION TO THIRD PARTIES
We cannot provide all services necessary for the successful operation of the Apps by ourselves. We must therefore share collected information with third parties, including analytics providers, tracking providers, third party advertising providers and other third party service providers that support the Apps (collectively referred to as “Partners”). We may share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’s advertising campaign performance. We may share such information to:
- Our analytics providers: For some Apps we use third party analytics such as BigQuery, and Firebase Analytics for the purposes of delivering our services, conducting analysis and research. To get more information about how your data is being collected and processed you can visit the site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. Additionally we have also integrated Google Play Developer Console data like Impressions, Downloads, and Traffic Sources into a Google Analytics account to see how many times people viewed or downloaded our apps from Google Play. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. Third party analytics providers have the right to process the data in accordance with their privacy policies (http://www.google.com/intl/en/policies/privacy/#nosharing) and such collection and processing is limited to the disclosure in aggregated manner, for the purposes of showing trends about the use of their services, for advertising services and marketing purposes. We can aggregate the data for benchmarking feature.
- Our cloud service providers: We store information we collect from you on servers provided by our third party cloud service providers such as Google Cloud Platform and Google’s Android Backup Service;
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.
We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.
For any additional questions about third party information collection please refer to firstname.lastname@example.org.
HOW OUR PARTNERS MAY USE YOUR INFORMATION
Some of the Apps allow you to submit content generated in or by the Apps to third party sites like Facebook, Vkontakte, Google Play Games, Game Center and YouTube. These submissions follow the information transfer protocols of such third parties, which are designed to enable content sharing with such third parties.
When you use our Apps we may display contextual advertisements to you. In order to enable advertising we allow our advertising partners to collect online identifiers (such as Advertising ID on Android and IDFA on iOS) that might be considered as personal information under some legislations, but they should use it solely for the purposes of contextual advertising. For any other purposes they should use the information solely on anonymized and aggregated basis.
When you use the App, we or third parties operating the advertisement serving technology may use information logged from your device using cookies, web beacons and other technologies to ensure that appropriate advertising is presented within the App and to calculate the number of unique and repeat views of advertising.
In addition, our Partners may use their own tracking technologies (including and without limitation: cookies, Web beacons, HTTP cache, local shared objects and other technologies) in order to track impressions, clicks, installs or other advertising campaign performance indicators for the purposes of measuring third party advertising campaign performance.
THIRD PARTY SOCIAL NETWORKS
1. Connecting To Third Party Social Networks
2. Data We May Access Via Third Party Social Networks
If you use the “Log in with” or “Connect to” feature we may access and store some or all of the following information, as allowed by you, Third Party Social Networks and your preferences: (i) your basic information from your public profile, such as your name, surname, profile picture, age range, gender, and other public information; (ii) email address, login ID and/or player identifier string (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the “Log in with” or “Connect to” process. We may share your name, profile picture and your game data (such as moves, App progress and scores) with respect to the applicable App, with your friends who have also used the “Log in with” or “Connect to” feature in connection with such App or with your contacts in applicable Third Party Social Media Network account.
The App may further ask you to allow us to post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates). Please keep in mind that we will only do that if specifically allowed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the App on your device so that the App will be able to communicate with Third Party Social Network directly; Voice recordings from Apps are also only being collected and stored within the Apps solely upon your request.
THIRD PARTY TERMS AND CONDITIONS
Please note that your access to and ability to use and interact with the Apps may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, online gaming platforms, social networking services, statistics services providers and payment providers. You recognize and agree that FREEDAY is not liable for any such third party terms and conditions and their use of your personal information.
Our Apps may contain links to third party websites, products, or services. For example, the Apps may feature offers from third party advertisers or the ability to engage in transactions with such entities. Please note that while using such third party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We are not responsible for the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party’s privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. These other websites or services may place their own cookies or other files on your computing device, collect information or solicit personal information from you. We encourage you to learn about the privacy practices of third parties with which you interact.
We are not responsible or liable for your interaction with such third parties, the information requests initiated by such third parties, or the subsequent use, treatment or dissemination of information you voluntarily choose to provide to them.
We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed to, and we do not knowingly collect personal information from children under 13, with the sole exception of persistent identifiers as described below. If we learn that we have collected personal information other than persistent identifier of a child under the age of 13, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at email@example.com.
In order to preserve the family-friendly reputation of our Apps, we age-gated some of the features in our Apps, so that they are not available for use by children under 13. The age gate is being conducted after the download of some of our Apps for specific territories in order to assure the privacy and protection of younger users of our Apps. The features enabling potential collection and sharing of personally identifiable information, with the exception of persistent identifiers, are disabled for device IDs of users who did not pass the age gate. For user’s safety, it is not possible to change the age later on. We do not store the year of birth of users who have identified themselves as below the age of 13 in our Apps, but only the information that their device ID did not pass the age gate.
The only personal information we collect from users who have identified themselves as below the age of 13 for the purposes of offering our services are persistent identifiers (such as device ID, IDFA, IDFV, advertising ID, IP address). Such persistent identifiers are used and shared with third parties solely for providing support for the internal operations meaning to place contextual advertisement (including frequency capping), to authenticate users of or personalize the content on Apps, to maintain or analyze the functioning of the Apps, personalize the content of the App (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the App, to ensure legal or regulatory compliance.
Opting Out of IBA:
1. Via third party IBA providers
For FB Ads please visit https://www.facebook.com/settings?tab=ads;
For InMobi Ads please visit http://www.inmobi.com/page/opt-out/;
For Google (Adx) please visit https://www.google.com/ads/preferences/html/mobile-about.html;
For Google (AdMob) please visit https://www.google.com/ads/preferences/html/mobile-about.html;
For AppLovin please visit https://www.applovin.com/optout;
For AppOnboard please visit http://apponboard.com/privacy/#optout;
For Vungle please visit https://vungle.com/opt-out/;
For PubMatic please visit https://pubmatic.com/legal/opt-out/#IBA;
For AdAction please visit https://www.networkadvertising.org/mobile-choices;
For AdColony please visit https://www.adcolony.com/privacy-policy/#targetingchoices;
For Apple (Search Ads) please visit https://support.apple.com/en-us/HT202074;
For Google (Ad Words) please visit https://support.google.com/ads/answer/2662922?hl=en;
If you choose to opt out by following one of the third party IBA provider’s opt out mechanisms, you should stop receiving ads based on your interest via the selected third party IBA provider, but you may continue to receive interest-based or targeted ads via other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options 2. and 3. below.
2. Via “Do Not Track Settings” in mobile phone
If you choose to opt out via “Do Not Track Settings” in your mobile phone all providers of advertising services are bound to comply with such “Do Not Track” setting, but we cannot provide any guarantees on their behalf. If you choose the opt-out option available via our Apps, we will not share your advertising ID with advertisers for the purposes of IBA. We provide no guarantees regarding the information provided prior to opting out. Some providers may have additional opt-out mechanisms implemented.
If you turn on “Limit Ad Tracking” on your iOS device or “Opt Out of Interest-Based Ads” on your Android device, you can restore interest-based ads by turning the settings off. When you opt out, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on your interests. Our advertising partners may continue to serve you ads based on other non-personal information, such as ads related to the content of the application you are using.
Your iOS or Android mobile device may provide a “Limit Ad Tracking” or “Opt Out of Interest-Based Advertising” setting. When you have opted out using this setting on a device, our partners will not use information collected from that device to infer your interests, or to serve ads to that device that are targeted based on your inferred interests.
You can find the setting for your mobile device by following the directions below, or contact your device provider.
The reason for switching from device IDs to Advertising Identifier is that advertisers are able to use this identifier only for advertising and for no other purpose, while users can choose to opt out of tracking via the settings of mobile phone. Advertising Identifier is an anonymous identifier for advertising purposes which enables users to reset their identifier or opt out of interest-based ads. The parties participating in advertising are obligated to follow users’ choice for opting out of tracking according to the app store guidelines.
Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
Go to your Settings > Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting
More information about the iOS setting can be found here: https://support.apple.com/en-us/HT202074
For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up:
Open your Google Settings app > Ads > Enable “Opt Out of Interest-Based Advertising”
Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the app store via your app store account. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store.
SPECIAL PRIVACY FETAURES IN SOME OF OUR APPS
Some of our Apps offer you to compete and interact with your Facebook friends, but you need to login with your Facebook account. By doing so, the App will receive your public profile and the list of friends. If you do not want to share the list of friends with the App, you can uncheck the box next to the permission for sharing the list of friends in the notice that appears during the “Log in with Facebook” . If you choose to login with Your Facebook account, the App will show Your public profile to your Facebook friends.
Some of our Apps can be played in a single or a multiplayer mode. In a multiplayer mode you can play matches with random players or your Facebook friends. Such Apps will ask you to choose your name. Please do not choose your real name. You can always change your name by going to “Settings” and selecting “Change Name”. The name you enter and your rank will be publicly displayed when playing with random players in a multiplayer mode. In order to play matches with Your Facebook friends, you need to login with your Facebook account. By doing so, the App will receive your public profile and the list of friends. If you do not want to share the list of friends with the App, you can uncheck the box next to the list. However, you cannot play matches with your Facebook friends without giving the App the permission to share your public profile. If you choose to login with Your Facebook account, the application will show Your public profile when playing with your Facebook friends or random players.
PROTECTION OF PERSONAL INFORMATION
INTEGRITY OF PERSONAL INFORMATION
We strive to enable you to keep your information accurate, complete and up to date. You can access, check and ensure the integrity of your information as described below.
ACCESS TO PERSONAL INFORMATION
We make good faith efforts to provide you with access to the personal information you provide to us (information associated with your account). You can also request that we correct or delete information, provided that we are not required to retain such information by law or for legitimate business purposes.
We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction or deletion requests regarding your personal information may be submitted to firstname.lastname@example.org. For some of our Apps we may develop in-app deletion request functionality which can be used in addition to the address above.
STORING OF INFORMATION
We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need them for providing our services.
Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our services.
DELETION OF INFORMATION
When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.