Privacy

Policy

mobile applications and other online products This Privacy Policy explains how Overulez Indie (”Overulez”, “we”, “us”) collect, share and use personal information when you use our games, mobile applications and other online products and services, about you, and how you can exercise your privacy rights. The Services are governed also by the Terms of Service and by the Cookie Policy. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date of the Privacy Policy and, in some cases, we may provide you with additional notice (such as by adding a statement to the homepage of our Services or sending you a notification). If you do not agree to the changes, please do not use our Services or otherwise provide us with your personal information. Information we collect Information You Provide to Us Certain parts of our Services may ask you to provide personal information voluntarily. For example we will ask you for certain information in order to register for an account with us, request customer support, to begin playing Games, to subscribe to marketing communications from us, and/or to submit enquiries to us. The types of informations we may collect can include your username, password, email address and any other information you choose to provide. Information We Collect Automatically When you access or use our Services, we may also collect certain information automatically about you, and/or your device which may be considered personal information under applicable data protection laws, such as: • Usage Information Data and analytics about your use of our Services including gaming service ID, levels completed, game scores, time spent using our Services, and other game play information • Log Information Your use of the App, including the type of device you use, the features you use, access times and your IP address. • Device Information The device you use to access the App, including information about the device’s software and hardware, unique device identifiers (i.e. Device ID and Advertising ID) , device tokens for push-messages, mobile network information and time zone • Location Information Geographic location of your device each time you use the Services provided on iOS or Android platforms, or otherwise consent to the collection of this information. You may opt-out of the collection of platform provided location data using the settings on your device. Your location is stored for the period specified in the Services before collection. • Consumption information Your consumption habits relating to your use of the App, including which purchases you make with both virtual and real currencies and the reception of virtual goods in-game Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile device that advertisers use for interest based advertising. They are consistent across all apps and thus allow cross-app tracking. On Apple you can opt-out this by choosing “limit ad tracking” option from privacy settings. On Google Android you can opt-out by choosing “Opt- out of interest based ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications. Device identifier / information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application. Some of this information may be collected using cookies and/or similar technologies (such as "SDKs" or software development kits) Information We Collect From Other Sources We may also obtain information from other sources as far as it is necessary to perform our Services. For example if you log into the App using a third party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friends lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent. If you log into the App using a third party site or platform, you represent and warrant that (i) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions. Use of information We use information about you for the following purposes as described below: • To create user accounts / profiles to enable you to play our Games and/or to have more functions when you play our Games • Send you technical notices, updates, security alerts and support and administrative messages • To enable you to communicate with other users (including via chat rooms, lobby room and/or private messages) • To respond to your customer support requests (e.g. if you write to us with a complaint) • To provide news and information about the App that we think will be of interest to you • To monitor and analyze trends, usage and activities in connection with the App and our Services • Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity • To track game installs (for purposes of measuring the effect of marketing campaign) • To remember you next time you visit one of our Services • To provide you with in-Game offers and rewards based on your in-game behaviours • To serve you with relevant targeted advertisements (necessary to fund our Services) • For any other purpose required or authorized for us to comply with our legal and regulatory obligations Sharing of information We do not sell, transfer or otherwise exchange your personal information with third parties, unless required for the provision of our products or services, otherwise in accordance with this Privacy Policy, or permitted by law or unless you have given us consent. We disclose information about you to the following categories of recipients: • Other players in order to provide certain in-app features, such as leaderboards, lobby room, turn interact games, or if you log into the App using a third-party service, such as Facebook or Apple Game Center or Google sign-in • Advertising network companies in order to serve contextual advertisements (the data include your IP-address, Device ID and Advertising ID) see more under “Advertising” • Social networks , see more under "Social Sharing features" A list of our current service providers and partners is available here. Social sharing features Our apps offer social sharing features and other integrated tools (such as the Facebook “Like” button, score, leaderboards, achievements, lobby rooms), which let you share actions you take in the App with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in the App. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. The App has social features from the following providers: • Facebook • Apple Game Center • Google Play Game • Overulez servers For more information about the processing carried out by the respective third parties in connection with social sharing features, please visit the privacy policies of the entities that provide these features, which can be found here: • Facebook (https://www.facebook.com/abo ut/privacy/) • Apple Game Center (https://www.apple.com/legal/in ternet- services/itunes/gamecenter/) • Google Play Game (https://support.google.com/goo gleplay/answer/2954594) • Overulez servers (this privacy policy) Advertising and Analytics Services We use advertising to fund our Services and to make our games and apps available for free. We show third party advertising in our games and also advertise our Services via third parties. These entities may use technologies to automatically collect information about your device and your use of our Services, including IP address, device ID, time spent on pages within our Services, and links clicked within our Services. This information may be used by us and others to, among other things, maintain, improve, and analyze the functioning of our Services and deliver contextual or targeted advertising that may be of interest to you. The use of your information (Advertising ID and IP-address) by these third parties is covered by their respective privacy policies, and we do not control and are not responsible for the privacy practices of third parties. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy listed here. We do not control which specific ads are shown in our games (this is controlled by ad networks) but we do blacklist certain categories of ads. We also advertises our games on other apps by asking ad networks to serve its to audiences that will be interested in them (determined using Advertising IDs).. You can opt out of interest based advertising on mobile applications by changing the privacy settings of your device and selecting "limit ad tracking" (Apple iOS) or "opt out of interest based ads" (Android). Security We take reasonable technical and organizational measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no transmission over the internet can ever be guaranteed secure so we cannot guarantee the security of any personal information that you transfer over the internet to us. Storing and deleting data Personal information collected through the Services is being stored and deleted in compliance with privacy requirements and/or as long as necessary in order to provide you with the App. All data will be anonymize or deleted if no longer required for the purposes mentioned above, unless further retention is required by law. Push Notifications/Alerts We may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device. We will send push notifications or alerts with promotional content only after your prior opt-in to receiving such messages on your device. International Transfer of Data Personal information that we collect from you is usually transferred, stored and processed in Italy. Please be aware that we will in certain circumstances transfer your personal data outside of your country which may not offer the same level of data protection as your country’s laws. When we transfer personal data to entities in third countries, we take such steps as are reasonable in the circumstances to ensure it is used in accordance with this Privacy Policy. Age Limit When we collect personal information we do not know the age of our players. In case a player has a Facebook account and has logged in to a game, we will get the age information from player’s Facebook profile information. If we learn that we has inadvertently gathered personal information from a child under 13 years of age, we will take reasonable measures to promptly erase such personal information from our records. Your Rights You, and your legal guardian if you are a minor, may be able to exercise certain data protection rights under applicable law. If you wish to use any of the rights described below, you may contact us at any time by emailing us at : info.privacy@overulez.com We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR. Your rights under applicable law may include: • To access correct, update or request deletion • The purposes of the processing • The right to withdraw your consent at any time for consent we have obtained from you, although this will not affect the lawfulness of the processing prior to the withdrawal • The categories of personal data concerned Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims. Contact Overulez Indie has the following contact information : Address : Via S. Antonio, 21047 Saronno Italy Email : info.privacy@sudokusquare.com Please note that other third parties (our data partners) may be data controllers of your information. You can find details of the third parties that we work with from here. Applicable from Oct 29, 2018