LAST REVISED ON: JULY 9th, 2019
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We will post any modifications or changes to the Notice on our App. We reserve the right to modify the Notice at any time, so we encourage you to review it frequently. If we make any material change to the App, we will post a notice on our App and at [http://www.funzio.com/privacy.html] prior to such change taking effect.
We only process your personal data in accordance with applicable data protection legislation, including but not limited to the (EU) General Data Protection Regulation (2016/679) and applicable national data protection legislation (hereafter "applicable law"). For the purpose of EU data protection legislation, the data controller is Deca Games EOOD of 15 Tsanko Tserkovski Str. Veliko Tarnovo 5000, Bulgaria.
Information we collect
We collect information about you in a range of forms, including personal data. As used in this Notice, "personal data" means any information which, either alone or in combination with other information we hold about you, identifies you as an individual.
We collect information about you in the following ways:
Information You Give Us: This includes the personal data you provide in the App settings such as your preferred language, redemption codes, and other preferred settings.
Information Automatically Collected: We automatically log information about you and your mobile device when you use our App. For example, when using our App, we log your mobile device ID, device advertising IDs, IP address, MAC address, mobile device operating system name and version, manufacturer and model, screen resolution, how long you spent using our game, access times and information about your use of and actions on our App. If you connect your Facebook account, we will also collect your first and last name, gender, Facebook ID, Facebook username, and timezone.
Use of Personal Data
We use your personal data to provide the App to you in accordance with our Terms of Service. In addition, when we use your personal data the legal basis for doing so may be our legitimate interest in providing you with an App that works well for you and other users and in order to monetise the App (such as when you purchase items in the shop function). More specifically, we use your personal data as follows:
- to operate, maintain, and improve our App;
- to operate and administer promotions you participate in on our App;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- to enforce our Notice and to protect our rights;
- to display advertisements
- to process payments for virtual currency that you purchase through the App Store or Google Play; and
- as described in the "Sharing of Personal Data" section below.
We may also use your personal data to comply with applicable laws and to comply with lawful requests and legal process, including responding to requests from public and government authorities. In some case we may also use your personal data to protect the vital interests of you or others.
Sharing of Personal Data
We may share your personal data as follows:
- Third Parties Designated by You: We may share your personal data with third parties where you have provided your consent to do so.
- Our Third Party Service Providers: We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data. Our main service providers are currently: Adecco, Amazon Web Services, Google Cloud, GodSpeed Gaming Solutions, ZenDesk, Splunk, DataDog, Xsolla.
- Third Party Advertisers: We may share personal data with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We currently share your device ID and device advertising ID with the following companies for the purpose of personalising the ads that you see: Vungle, AppLovin, AdColony, Fyber, Unity Ads, Google AppsFlyer, AdMob, Facebook Audience Network, myTarget, Adjust, Tapjoy, and IronSource. You can prevent the use of your device ID and advertising ID using the settings on your mobile device.
- Corporate Restructuring: We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transactions or proceedings.
- Other Disclosures: We may share personal data as we believe necessary or appropriate to comply with applicable laws and to comply with lawful requests and legal process, including responding to requests from public and government authorities. In some case we may also share your personal data to protect the vital interests of you or others.
When we use the term "anonymous data", we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using, for example, your device ID or IP address. We make personal data into anonymous data by excluding information (such as your name or device ID) that makes the data personally identifiable to you. We reserve the right to use anonymous data for any purpose and to disclose anonymous data to third parties in our sole discretion.
Third Party Sites
Our App may contain links to third party websites and features, such as being able to support our social networking pages. This Notice does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
International Data Transfer
Information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our third party service providers outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in the country in which you reside or in other parts of the world.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Notice. This includes the use of the Privacy Shield for transfers to the USA as well as the European Commission's Standard Contractual Clauses. Further details can be provided upon request.
We seek to use appropriate organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us using the details in the Contact Information section below.
You have the following data protection rights:
- to access, correct, update or request deletion of your personal information;
- object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information; and
- 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.
Similarly, if we have collected and process 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 on lawful processing grounds other than consent.
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. (Contact details for authorities in the UK, European Economic Area, Switzerland and certain non-European countries (including the US and Canada) can be found by clicking these links).
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We will retain your personal data for the period necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required or permitted by law.
Our Policy on Children
Our App is not directed to children under 16 and may only be used by children with the consent of their parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Information section below. We will delete such information from our files as soon as reasonably practicable.
Sensitive Personal Data
We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership, sex or sexual orientation) on or through the App or otherwise to us.
We welcome your comments or questions about this Notice. You may contact us in writing by email at firstname.lastname@example.org.