The option for our partners to display interest-based, or retargeted, ads (''IBA'') is enabled solely 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.
We will pass only the device-level data to our advertising partners (for example if a device has clicked on a sports ad within our apps) and they can reuse such data for targeted advertising. We allow our partners to serve targeted third party advertisements or other content. They may attach the information gathered from your device to info gathered from other apps, websites, or via other services, and then build profiles and transfer the info to another provider. For example we pass advertising IDs to FB and they match it with your FB ID, aggregate it and delete the initial identifier. By doing so the other provider may receive or gather information about you and use the information for displaying targeted ads. Advertisers may choose their audience by location, demographics, likes, keywords, age & gender, interests, behaviors, connections and any other information FB receives or infers about users. We cooperate with several providers of IBA, Facebook, MoPub, InMobi, Google (Adx), Google (AdMob), AppLovin and My.Com (''Third Parties''). When allowing Third Parties to conduct IBA we adhere to the DAA Principles available here http://www.digitaladvertisingalliance.org/principle/index.html.
b) Turn on “Limit Ad Tracking” on your iOS device or “Opt Out of Interest-Based Ads” on your Android device
c) Choose “Opt Out of IBA” within the settings of our apps (where available).
Collection of Device and Technical Information
We collect the data necessary for you to use our app and for us to maintain and analyze the functioning of the app, to personalize the content of the app, and to display contextual advertisements.
We automatically obtain certain information about your computing device, including:
Although some of this information (such as IDFA, IDFV, Advertising ID, Android ID, IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US) may treat information that uniquely identifies your device as personal information.
Older versions of our Applications may still obtain information such as UDID number and IMEI number on iOS. If you wish to prevent this, please update the Application with the latest version available on App Store.
Collection of Advertising and Application Usage Information
When you use the Applications or the Websites, we may collect additional information by using device identifiers in a form that does permit identification of your device. The information collected includes:
Collection of Classical Personal Information
We may also collect personally identifiable information about you (such as your name and surname, email address), as well as non-personally identifiable information (such as specific age or age range and gender) that you provide us, by using our Applications, when you voluntarily register with SMeiTi, request information using the Websites or contact us directly.
We will only use the contact information you provide to us (for example, your name and email address) for the purpose for which you provided it to us. We will not share this data with third parties.
If you wish to delete your contact information that we received upon your specific email inquiry, please send an e-mail to email@example.com and your e-mail will be deleted from our database.
Sharing of Information Upon Your Request
We access your social network profile if you allow us to for the purposes of using in-game features.
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 profile, such as your name, surname, email address, login ID, player identifier string; (ii) your photos and videos. The Application may further ask you to allow us to (i) post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates) and to (ii) manage your notifications (access your notifications and mark them as read). Please keep in mind that we will only do that if specifically directed 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 Application on your device so that the Application will be able to communicate with Third Party Social Network directly; Voice recordings from Applications are also only being collected and stored within the Applications upon your request.
Consent to Public Display of Data upon your acceptance
We may publicly display your data when you participate in game related activities for the purposes of user identification.
Collection of Data Log Files
To make our apps appealing to users, we must collect data logs about the usage of the app by you. But don't worry, personal data is obfuscated/deleted within the app before we receive it and we tie the data to an ID that cannot be traced back to you.
The Application might automatically send anonymized and obfuscated data log files to us that contain detailed information on your usage of the Application (e.g. data log files containing chat history, where (i) such history cannot be attributed to any individual person; and (ii) any personal details that you provide us voluntarily (e.g. personal names, addresses, numbers, places, etc.) are obfuscated/deleted within an app before they are sent to us). The data logs from you shall be assigned an ID that cannot be traced back to your device and your device identification shall be immediately deleted from our system. Such data log files are used solely for the purpose of analysis, development and improvement of individual functions within the Application with the aim of making the Application more appealing to users. The data logs will not be disclosed to third parties. Implied but informed consent shall be deemed given to us by downloading and using the Application.
We will use such statistical data that may be connected with your device ID only for our internal purposes of developing, delivering, improving, personalizing and tailoring our products, services, content, and understanding and analyzing trends in connection with the usage of the Application, and administering the Application and customer communications.
Our Use of Information
We use the information we collect from you for delivering and promoting our services, internal analysis and research to improve the services and to display advertisements.
We use the information we collect about you/your computing device to deliver services to you and to operate our business. Such use by us and by our Partners may include:
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 e-mail and/or 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, which Products have been bought or have been considered, 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 Application 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 do not wish to receive promotional, marketing or research materials please send an e-mail to firstname.lastname@example.org and your e-mail will be excluded from our user database. If you do so you will no longer receive special and discount offers from us. 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.
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.
Disclosure to Third Parties
We disclose the information to our advertising and analytics partners so that we can display advertisements and analyze the usage.
We cannot provide all services necessary for the successful operation of the Applications or the Website 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 Applications and the Website (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 advertising campaign performance:
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Applications or the Website. 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.
Use of Information by our Partners
We strive to commit our Partners to using the information solely for the purposes as stated above. If they use information that might be considered as personal information, they should use it solely for the purposes of contextual advertising, but for any other purposes they should use the information solely on anonymized and aggregated basis. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices. While we strive to protect the information provided to our Partners, we have no direct control over their use of the collected information and therefore you acknowledge that we are not liable for any third party privacy breach and that our liability for our Partner breaches is limited to the amount we are able to receive as indemnification from our Partners (legal costs exempted).
In addition, Partners may use their own tracking technologies (including and without limitation: cookies, Web beacons, HTTP cache, and local shared objects) to compile anonymous information about users of the Applications and visitors to the Websites. Partners may share anonymous information that they collect with their clients, including the date and time a banner ad was shown and the specific ad shown. We strive to ensure that this information is only disclosed to such third parties in an anonymized and aggregated manner.
Some of the Applications allow you to submit content generated in or by the Applications to third party sites like Facebook, Vkontakte, Google Play Games, Game Center and YouTube. These submissions follow the information transfer protocols for such third parties, which are designed to enable content sharing with such third parties.
Third Party Terms and Conditions
Please note that your access to and ability to use and interact with the Applications and the Websites 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 SMeiTi is not liable for any such third party terms and conditions and their use of your personal information.
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
Access, correction or deletion requests regarding your personal information may be submitted to email@example.com.
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 can be made through the SMeiTi website at http://www.smeiti.com/. For some of our Applications we may develop in-app deletion request functionality which can be used in addition to the address above.
INFORMATION COLLECTION RELATING TO CHILDREN
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. If we learn that we have collected personal information of a child under 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 firstname.lastname@example.org.
In order to preserve the family-friendly reputation of our Applications, we age-gated some of the features in our applications, 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. If you do not pass the gate the features enabling potential collection and sharing of personally identifiable information are disabled for your device ID. For your safety, it is not possible to change your age later on. We do not store your year of birth but only the information whether your device ID passed the age gate or not.
The only personal information we collect from you 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 Applications, to maintain or analyze the functioning of the Applications, personalize the content of the Application (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the Application, to ensure legal or regulatory compliance.
Third Party Sites
Our Applications, Websites, products and services may contain links to third party websites, products, or services. For example, the Applications 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.
Our Applications enable in-app purchases.
Although some of our Applications are free, they include in-app purchases. In-app purchases may be made only upon entering the app store password and you are responsible for maintaining the security of such password. Your authentication and security maintaining is subject to specific terms of the app store and the OS of your mobile device. You should be aware of the iOS’ 15-minute and Android’s 30-minute window after the downloading of an Application, during which in-app purchases may be made without inserting an in-app store password. You should also take into account that OS 2.1 or older versions of Android mobile phones do not require entering of the app store account password to carry out in-app purchases.
Opting out of IBA:
For MoPub Ads please visit http://www.mopub.com/optout/;
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 My.Com please visit https://target.my.com/privacy/;
For OpenX please visit http://openx.com/legal/privacypolicy/interestbasedadvertising/;
For Inneractive please visit http://inner-active.com/privacy-policy/;
For Machine Zone please visit http://www.networkadvertising.org/mobile-choices;
For Madgic please visit http://www.madgic.com/opt-out-and-identifier-reset/.
The providers of advertising services are bound to comply with “Do Not Track” settings in mobile phones, 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 device ID with advertisers for the purposes of IBA; or, if already shared, we will remove it from their services. 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”
We are creating an opt-out option within some of our apps. You may choose it by visiting ''Info Screen'', ''Settings'' and ticking the ''Disable Interest-Based Ads''. Choosing this option will mean that you will still be served ads, but they will not be tailored to your preferences. Should you decide to opt out of advertising altogether, you may make an in-app purchase to do so, or you can delete the app.
Opting out from FIREBASE analytics
Our apps may use Firebase Analytics. 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/. We have created an opt-out option within our apps that use Firebase Analytics. Should you decide to opt out, you may do so by visiting ''Info Screen'', ''Settings'' and ticking the ''Opt Out of Analytics'' button.
Any questions? Send us an e-mail to email@example.com.