PLARIFY - PRIVACY POLICY

Last change: November 2019

Introduction

Plarify Ltd. (" Plarify ", " we ", " our " or " us ") develops, publishes and operates social games for web and mobile environments (" games ") as well as for web and mobile applications (each an " app ") to play our games across multiple devices and platforms (such as mobile devices and Facebook).

We also operate the website www.plarify.com, its subdomains and related features (" Website ", and together with the Games and the App, collectively - the " Services ").

Plarify respects your privacy and strives to make our practices regarding your information more transparent and fair. This privacy policy describes how we collect, store, use and transmit your personal information. They apply when you visit our website, install our app and play our games, interact with us or otherwise access or use our services.

Specifically, these privacy notices describe our practices regarding -

  1. Data collection

  2. Use of the data

  3. Advertising use

  4. Storage and storage

  5. Data transmission

  6. Cookies and tracking technologies

  7. Communication

  8. Data security

  9. Rights of data subjects

  10. Minors

  11. Updates & How to contact us

We urge you to read these instructions and to ensure that you fully understand and accept them. If you disagree with these instructions, please stop using our services and avoid their use in the future. You have the right to discontinue the use of our service at any time in accordance with this privacy policy.

You are not legally obligated to provide us with personal information, but without it we will not be able to provide you with the full scope and experience of using our services (eg you can play our games without Connect your Facebook account, but you will not be able to enjoy their social features). 

This Privacy Notice is part of and integrated with the Plarify Terms and Conditions. The terms and conditions are currently available at: https://plarify.com/terms/

1. Data collection

We collect four major categories of data (and to the extent that they allow for the identification of a particular person or are associated with such potentially identifying information, we consider them " Personal Information "):

  1. Automatically Collected or Generated Information :
    Whenever someone visits, interacts or uses our Services, including any email or text message sent to us by us or through our services, we may collect or generate technical information about them. We collect or generate this information either independently or through third-party services (as described in Sections 4 and 6), including through the use of "cookies" and other tracking technologies (as further described in Section 7). This data consists of connection data, technical or aggregate usage data, such as the IP address, the so-called Unique Advertising ID (eg IDFA, you can reset this ID by following the instructions below), unidentified data about a device, Operating system, a browser or app version, a wireless service provider, country and language settings, user activity on our services, and in-app or gaming events. We do not use this data to discover a person's true identity or contact information, but, more importantly, to better understand how our users typically use and interact with our services. Use of such technical and device-related data also helps us and our partners provide interest-based or otherwise more effective advertising and content, streamline our ad management and our users' image experience, and improve the overall performance and user experience of our services. For more information about our promotional use, see Section 4.

  2. Information You Receive: You may voluntarily provide us with personal information, such as when you contact us (via Facebook, Messenger, e-mail, or any other channel, including any support services) when you post to our public forums or groups if you provide us with your e-mail address (eg when you sign up for e-mail updates or gifts), when you make purchases in one of our games, when you interact with other users or when you decide to do so To connect your Facebook account to one of our games.

  3. Data received from Facebook and other channels : Once you have connected the game to your Facebook account, we will gain access to your public Facebook profile, including (as far as you have defined it as "public") your full name, ( The email address you provided to Facebook), gender, location, your time zone, and a list of your friends playing the game. It also allows us to present the public profile pictures of yourself and your friends within the game, but we will no longer keep them on our servers as required to share them with the app from Facebook. In addition, we or our advertising partners of Facebook and our other marketing channels may receive general information about the performance of our advertising campaigns, such as the age target group or interests. We or our affiliates may associate this general data with all other data in our possession (to read more about our advertising practices, please read section 3 below). If you access our services through a third party such as Facebook or connect our services to an account with a third party, you should read its terms and conditions and privacy notices. If you are not sure what information a third-party application shares with us, please visit the website of this third-party application to learn more about their privacy practices.

  4. Transactional Data : In-game purchases are typically handled by the respective platform provider (eg, Apple, Google, or Facebook), and we will not collect or store your financial information, such as your credit card numbers or bank account. However, we may receive your non-financial personal information in connection with the purchase, such as your name, billing address, e-mail address and purchased items to process your purchase and for our accounting purposes.

2. Use of the data

Our legal basis for the collection and use of your personal information is determined by the purpose for which your data is processed, but we generally use the following:

  1. "Performing a Contract": We will use this basis for the processing required to provide you with the Game, including so-called "Social Gaming" when you log in via Facebook, as well as the Support Services, and to send you service messages.   

  2. Consent: In limited circumstances (if you sign up to receive direct marketing e-mail and accept cookies on our website) we will process your personal information based on your consent. You can revoke your consent at any time by contacting us under the information given in section 11.

  3. "Eligible Interests": We process your personal information based on our legitimate interest in maintaining and improving our services and offerings, understanding our use of our services, providing effective advertising within our games and through other channels, improving our customer service and service our support measures, as well as the protection and security of our users, our own protection and the protection of our services.

  4. "Legal Obligation": In limited circumstances, we may process your personal information because we must do so in order to comply with a legal obligation, such as that set forth in applicable law, or if we have such instructions from a court or regulatory authority receive.

The purposes for which we use personal information are described in more detail below:

  1. To facilitate, operate and provide our services;

  2. To authenticate the identity of our players and give them access to additional features;

  3. To provide our customers with customer care, support and technical support;

  4. To further develop, adapt and improve the Services and your User Experience based on general or personal preferences, experiences and difficulties;

  5. To more effectively manage and deliver advertising, including contextual, behavioral and interest-based advertising that is based on game progress and activity, based on your preferences or other data available to us or our business partners, including but not limited to: targeting purposes;

  6. To contact our users (via email, Facebook, push notifications, or other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance alerts); to contact our users with marketing messages (such as game updates, bonuses, new features, VIP services, etc.); and to facilitate, sponsor and offer certain events and promotions;

  7. To support and improve our data security measures, including the purpose of preventing and reducing the risk of fraud, error or illegal or prohibited activity;

  8. To create aggregated statistical information, derived non-personal information, or anonymous or pseudonymous data (which is not personally identifiable) that we or our business partners may use to provide and improve our respective services; and

  9. To comply with applicable laws and regulations.

3. Advertising use

Our games include advertising for third-party services and products. We and our affiliates use certain information about you to improve our advertising practices and make the ads we provide more effective, relevant and enjoyable, including through the use of interest-based advertising, targeting, ad measurements and performance analysis systems.

These data include your device advertising identifiers (eg IDFA, if available), data related to your affiliate Facebook profile (if available, such as your gender, region or country) and other demographic and interest-related information We or our affiliates may have received from or through you based on your consent or any other legal basis (ie, as necessary to provide you with our respective services or based on the legitimate interests described in section 3 above) ). Please note that we do not pass on the data you provide to us through your affiliate Facebook account to our affiliates . 

The advertisements that we or our affiliates distribute may be displayed within our games, our services, or through other channels, such as third party websites and applications.

This Privacy Notice does not apply to practices of companies that we do not own or control, or employees or service providers that we do not manage. All information that you provide to websites, applications or services that are advertised through our services is subject to the privacy policy applicable there. Please read the privacy notices of third-party applications, services, and websites that you visit or give permission to access. It is the responsibility of these third parties to protect all information that you give them, so that we can not be held responsible for the use of your personal information by these third parties.

How to customize your preferences for interest-based advertising

If you would like to prevent the use of your device's promotional ID or other interest-based advertising identifiers, you can change your device settings to reset this promotional ID or opt-out (see the "Privacy "or" Ads "available in your device settings).

If you live in the United States, Canada, or Europe, you may opt out of collecting data from our affiliates who are members of the Digital Advertising Alliance by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users).

Please note that if you reset your advertising ID or disable interest-based advertising, you may continue to see advertisements in our games or on other channels. However, this advertisement will not be played on the basis of the above identification features. For example, such ads may instead be based on context, such as your progress and actions in the game or your language preferences. Please note that this may result in a less enjoyable user experience.

Aggregated and analytical information

We can use standard analysis tools. The privacy practices of these tools are subject to their own privacy notices, and they may use their own cookies to provide their services (for more information on cookies, see the "Cookies" section of this note).

We use the standard analytics tools provided by Google Analytics and may from time to time use additional or different analysis tools. The privacy practices of these tools are subject to their own privacy notices.

Google Products: Google uses technologies such as cookies to track and analyze the use of our website and / or an SDK to display ads in our games. To learn more about how Google processes data, we encourage you to read Google's policies at https://policies.google.com/technologies/partner-sites. For more information, see the Google Analytics opt-out web tool at: https://tools.google.com/dlpage/gaoptout. For more information about the data that the Google SDK processes and stores, see: https://support.google.com/admob/answer/7665968  

We use anonymous, statistical or aggregated information and may disclose it to our partners or service providers for legitimate business purposes. This does not affect your privacy, as there is no apparent way to extract data from the aggregated information that can be associated with you.

4. Storage and storage

Your personal information may be managed, processed, accessed and stored by Plarify and our authorized affiliates, service providers and business partners in and out of the United States and other jurisdictions, to the extent required or required by law for the proper provision of our services. Plarify Ltd. is based in a jurisdiction which, according to the European Commission, provides an adequate level of protection of the personal data of persons residing in an EU Member State.

Although data protection laws may vary between jurisdictions, Plarify has taken reasonable steps to ensure that your personal information is treated in a secure and lawful manner by its affiliates and service providers in accordance with industry practice, regardless of minor regulatory requirements. which apply in their jurisdictions. When we transfer personal data from EEA users to countries outside the EEA that do not offer an adequate level of protection under the European Commission, we generally make such transfers dependent on approved data transmission agreements or, in the case of transfers to the US, we send them to recipients that are certified under the Privacy Shield. You can contact us using the information in Section 11 to learn more about these protections.

We store your personal information in order to maintain and develop our relationship and provide you with our services. In other words, we store your personal information as long as you remain our user and have not communicated anything else to us. We will take reasonable steps to delete your personal information when you delete your account. We may store your personal information for legal and accounting purposes in accordance with our Data Retention Policy (ie, as required by law for recording and bookkeeping, and to obtain evidence and evidence of our relationship in the event of legal problems arising under the Privacy Policy Setting your usage). If you have questions about our data retention policy, please contact us at info@plarify.com..

Please note that unless required by law, we are not required to keep your information for a limited period of time. We are free to permanently delete them for any reason and at any time with or without notice.

5. Data exchange

We may share your information with certain third parties, including law enforcement agencies, our service providers and our affiliates. The key circumstances in which we share information are summarized below:

  1. Compliance with Laws, Regulations, and Regulatory Orders : We may refer to law enforcement and law enforcement authorities in response to a subpoena, search warrant, or court order (or similar instruction) or in accordance with applicable laws and regulations, including for national security purposes, disclose or allow access to certain personal information. Such disclosure or access may be made with or without notice to you, if we have a good faith belief that we are legally required to do so, or disclosure in connection with efforts to investigate, prevent, or take action against you Actual or suspected illegal activity, fraud or other misconduct is appropriate.

  2. Service Providers and Business Partners: We may engage selected third parties and individuals to provide services that complement our own (eg, hosting services, data analytics services, marketing agencies and advertising services and tools, data and cybersecurity services, fraud detection and prevention services, payment processing services, services for user engagement, email distribution and monitoring services, session recording and our business, legal, financial and compliance advisors (collectively " service providers "). These service providers may, depending on their specific duties and purposes, have access to your personal information in facilitating and supplementing our services and may only use them for those purposes.

  3. Third Party Integrations: The Services allow you to integrate certain third party services, such as connecting your Facebook account to a particular game or making purchases. In this case, you are bound by the terms and conditions and privacy notices of these third parties (eg Apple, Google or Facebook) - please ensure that you read and accept these in advance. We do not receive or store your passwords for these third party services. 

  4. Protection of Rights and Security : We may disclose your personal information to others, with or without notice, if we have a good faith belief that it protects the rights, property or personal safety of Plarify, one of our users or the general public Public contributes.

  5. Plarify Affiliates and Affiliates : We may share personally identifiable information internally within our group of companies for the purposes described in these notes. In addition, if Plarify or one of its affiliates undergoes a change of control (including through the merger, acquisition or purchase of substantially all of its assets), your personal information may be shared with the parties involved in such event. If we believe that such a change of control could have a material impact on your personal information that is then stored by us, we will email you and / or you about this event and the choices you may have to inform by a clear reference in our services.

For the avoidance of doubt, Plarify may disclose your personal information in additional ways - with your express consent, or if we are required to do so by law, or if we have successfully used or anonymised that information. We may transfer, share, or otherwise use non-personal information at our sole discretion and without further authorization.

6. Cookies and tracking technologies

Our services and some of our service providers use "cookies", anonymous identifiers and other tracking technologies that help us to provide and improve our services, to personalize your experience and to enhance the performance of our activities and campaigns, and to use our apps, games and services to monitor in total.

A "cookie" is a small text file used, for example, to collect information about activities on our website. Some cookies and other technologies are used to retrieve personal information, such as an IP address previously transmitted by the user. For example, we may use cookies to store your language preferences or other settings so that you do not have to reconfigure them whenever you use our services. Some of the cookies we use are linked to your account (including personal information about you, such as the e-mail address you gave us), other cookies are not.

We use the following cookies:

  • Essential cookies. These are cookies that are required for the operation of our website. These include, for example, cookies, with which you can log in to protected areas of our website.


  • Analytical or performance cookies. These allow us to identify and count the number of visitors, and see how visitors move around our site when they use them. This helps us to improve the way our website works by, for example, ensuring that users can easily find what they are looking for.


  • Functional cookies. These are used to identify you when you return to our website. So we can personalize our content for you, welcome you by name and remember your preferences (eg your language or region choice).


  • Targeting cookies. These cookies record your visit to our website, the pages you visit and the links you follow. We will use this information to make our website [and the advertising displayed on it] more relevant to your interests. We may also share this information with third parties for this purpose.

Although we do not change our actions in response to a "Do-Not-Track" signal in the HTTP header of a browser or mobile application, most browsers allow you to control cookies, including the ability to choose whether or not to accept cookies want to or want to delete them. You can set most browsers to notify you when you receive a cookie, or you can block cookies with your browser. However, we can not guarantee that our services will work completely if you choose to block cookies. For example, any settings you made on our website or in our app will not be saved.

7. Communication

Service communication : We can contact you with important information about our services. For example, we may inform you (through any means available to us) about changes or updates to our services, billing issues, and so on. You are unable to log out from such service communication.

Advertising Communication : If you have signed up to receive such communications from us, we may also notify you of new services, events and special opportunities or other information that we believe to be of interest to you. We may provide such communications through any means of contact available to us (eg, telephone, mobile, or e-mail), through the Services, or through our marketing campaigns on other websites or platforms.

You have the right to revoke your consent to receive such advertising at any time. You can do this by sending us an e-mail to info@plarify.com or following the instructions "Unsubscribe", "Stop" or "Change E-mail Settings" in the received promotional communications.

8. Data security

To protect your personal information stored with us and our service providers, we use industry-standard physical, procedural, and electronic security measures, including encryption, where appropriate. Please note, however, that regardless of the security measures used, we can not guarantee and guarantee the absolute protection and security of the personal information held by us or the third parties described in Section 6.

9. Rights of the persons concerned

If we process personal information about you and if you are resident in the EU or resident in another jurisdiction that grants you the following rights, you will have:

  • the right to know which personal data we store about you.

  • the right at any time to access, rectify, or request the deletion of your personal data, to request a restriction of our processing or to object to the processing of your personal data, as required by applicable law. Please note that if you request us to comply with the applicable law, we may not be able to provide you with all of our services and customer support the way we use, process, restrict, or erase your personal information or that the quality of the services can be compromised.

  • the right to have your personal information transmitted in accordance with your data transferability right.

  • the right not to be subjected to a decision based solely on automated processing, including profiling, which will have legal effect or similarly affect you in a similar manner.

If you exercise one or more of the above rights in accordance with the provisions of applicable law or any other right under applicable law, we will, if necessary, provide third parties with your personal information in accordance with this Privacy Notice store, instruct, act accordingly.

If you wish to exercise your rights under applicable law (eg EU GDPR), please contact us at info@plarify.com..

Please note that once you contact us by email, we may need additional information and documents, including certain personal information, to authenticate and confirm your identity and to process your request. This additional information will then be stored by us for legal purposes (eg to prove the identity of the person submitting the application) in accordance with our data retention policy.

If you wish to manage the information we receive about you from a third-party application or platform (such as Facebook, Apple or Google) on which you play our games, please follow the instructions of the third-party application to update yours Information and to change your privacy settings.

You have the right to file complaints with a data protection authority. Details of your National Supervisory Authorities can be found at this link: https://edpb.europa.eu/about-edpb/board/members_en.

10. Minors

Our services and games are not geared to minors under the age of sixteen (16) . We do not knowingly or willfully collect personal information from minors. If we learn that a minor is using the Services or playing one of our games, we may prohibit such use, block it, and make every effort to immediately delete the personal information we hold about it.

If you believe that we may have such information, please contact us at info@plarify.com..

11. Updates; How to contact us

Updates and Changes : We may from time to time update and update these notes by posting a modified version on our services. The amended version will come into force at the time of the published cut-off date. We will notify you in advance by any of the means of communication available to us or through the Services, in the event of material changes. After this period, all changes are deemed to have been accepted by you. If you do not agree to be bound by the terms of the new or amended Privacy Notice, you must cease using the Services.

Questions, concerns, or complaints : If you have any comments or questions about this Privacy Notice, or if you have any concerns about your privacy or if you would like to contact the Plarify Privacy Manager, please contact us at info@plarify.com.