(Last update October 16, 2023)
INFORMATION WE COLLECT FROM YOU
When you visit our Websites, we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with promoting our apps and services, and for research or analysis.
1. Technical Information
We collect the data necessary for you to use the Websites and for us to maintain and analyze the functioning of the Websites and to personalize the content of our products.
We automatically obtain certain information about your computing device, including:
- IP address; Country code;
- Language; Locale (specific location where a given language is spoken);
- Time zone;
- Network status (WiFi, etc.), browser plug-in types and versions;
- Technical device information (e.g., device model and name, operating system name and version, screen size, mobile phone carrier, Internet service provider);
- Information we collect via the use of pixel tags in marketing emails that we send to you (where we have your consent to do so) to measure open, click through and read rates and allow us to improve our emails.
- Information we collect via the use of tracking links in marketing emails that we send to you (where we have your consent to do so) to measure click through and install rates to be able to evaluate how many users have downloaded the app.
Although some of this information (such as IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US and EU) may treat information that uniquely identifies your device as personal information.
2. Website Usage Information
When you use the Websites, we collect additional information from you by using persistent identifiers that permit identification of your device.
The information we collect includes:
- Website usage, including log information, that lets us know how you use the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);
- Characteristics obtained by your use, such as data about pages of our Websites that were viewed during your visit, any actions or movements within the Websites and movements to/from the website from/to another website, date and time, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
3. Classical Personal Information
If you wish to delete your personal information that we received from you, please send an e-mail to [email protected] and your personal information will be deleted from our database.
HOW WE USE YOUR INFORMATION
We use the information we collect from you for delivering our services and Websites and to operate our business. We use it also for improving our services and Websites, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services, Apps and Websites, for providing customer support and for complying with our legal obligations.
We use your technical, website usage and classical information for the following purposes:
- Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, enter into any promotion, using your IP address to determine which country you are based in in order to serve you a cookie notice, depending on applicable laws, understanding and analyzing trends in connection with usage of the Websites, administering the Websites, and customer communications.
- Promoting our Apps and Services: when you use our Websites we may promote our Apps and other Services, including new games.
- Analytics and research: Understanding and analyzing trends in connection with the usage of Website, auditing, learning about user behavior on the Websites (how often you use the Website, the events that occur on the Website, aggregated usage, performance data etc.). We also use information collected from pixel tags in marketing emails that we send to you (where we have your consent to do so) to measure open, click through and read rates and allow us to improve our emailing campaigns. We also use information collected from tracking links in marketing emails that we send to you (where we have your consent to do so) to measure click through and install rates to be able to evaluate how many users have downloaded the app.
- Security: We use your information for enhancing the safety and security of our Websites, apps, products and services.
- Customer Support: We use your information for providing customer support to you and to respond to your inquiries.
- Our legal obligations: We use your information when we are required to do so by law.
Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to "Do Not Track" signals or other mechanisms. For more information on "Do Not Track," visit https://www.allaboutdnt.com.
SURVEYS AND CONTESTS
We are conducting surveys and online contests in order to improve our services and you may freely decide whether you would like to take part in it or not.
From time to time, we may conduct an e-mail survey or an online contest and collect classical personal information, demographic information, usage information and other materials that you voluntarily submit to us for the purposes of internal analysis, marketing and brand development. Participating in a survey or an online contest is completely voluntary. We will use the information to make our services more appealing to users. Collected information gathered via surveys shall be anonymized and aggregated. We may use your information gathered via contests for the purposes of performing the contest and to contact you as per such contest's terms and conditions.
HOW WE SHARE YOUR INFORMATION
We cannot provide all services necessary for the successful operation of the Website by ourselves. We must therefore share collected information with third parties, including analytics providers, and other third party service providers that support the Website, including Third Party Social Networks (collectively referred to as "Partners"). We may share information that can be used to personally identify your device (e.g. IP address) for the purposes of delivering our services, displaying advertisements, promoting our apps and services and conducting analysis and research. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.
We may share such information to:
- Our affiliate, Outfit7 Limited, who provides several services for us, such as tracking, analytics, and is partnered with third party service providers for provisions of such services. For third party service providers of Outfit7 Limited, please check this link: https://outfit7.com/privacy-web/en/
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with 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.
If you have given us consent for marketing emails, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products and services.
You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to [email protected]
HOW OUR PARTNERS MAY USE YOUR INFORMATION
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 providing the service to us, 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.
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 visitors to the Websites. Partners may share anonymous information that they collect with their clients. We strive to ensure that this information is only disclosed to such third parties in an anonymized and aggregated manner.
THIRD PARTY TERMS AND CONDITIONS
Please note that your access to and ability to use and interact with 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.
Our Websites may contain links to third party websites, products, or services. 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 cannot control 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. We encourage you to learn about the privacy practices of third parties with which you interact.
We do not knowingly collect personal information from children under the age of digital consent according to the EEA data protection legislation. If we learn that we have collected personal information other than persistent identifier of a child under the age of 13 or under the age of digital consent according to EEA and UK data protection legislation, 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 protected].
In the event we discover we have collected information from a child in a manner inconsistent with Children's Online Privacy Protection Act (COPPA) requirements, we will either delete the information or immediately seek the parent's consent for that collection.
You have certain rights in connection with your personal information and how we handle it, i.e., you have a right to obtain information about whether we hold personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to [email protected].
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under data protection laws.
Your rights include:
- Right to object. In some cases you have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests (see Legal Bases below). You are always free to opt out from the future collection of your personal information by us and our Partners by stopping with the use of our Websites and services.
- Right of access. You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right, please contact us by letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for. Where we are not able to provide you with information that you have asked for, we will explain to you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
- Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via [email protected] and we will correct it as soon as we can.
- Data deletion. You have a right to request deletion of the personal information that we hold about you. Should you wish to do that, please contact us via [email protected]. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymised form.
- Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do that, please contact us via [email protected].
- Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
- Right to withdraw consent. Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us via [email protected].
- Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.
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.
The legal bases that we rely upon are the following:
- Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested - and that we have agreed - to provide to you, that is to deliver and improve our services, to provide customer support and to process your information in relation to online contests.
- Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when using our Websites and services, to make sure your information is secure and to provide to you our services free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics and research, for our own promotion purposes.
- Legal Obligation. This covers information that is processed by us to comply with a legal obligation.
We operate globally, so we need to transfer your personal information to our affiliated entities and/or to other third party service providers across border and from your country to other countries around the world. Please note, that not all of these countries have the same data protection laws as your own country, but wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.
We will transfer your personal information outside EEA only when the transfer is based on one of the following safeguards:
- To a country with adequate data protection. We will transfer your personal information outside EEA to a country that ensures an adequate level of protection in accordance with EEA data protection legislation.
- Based on standard contractual clauses. We will transfer your personal information to our Partner outside EEA, if we have entered into standard contractual clauses with such Partner, that are adopted by Commission of European Union in accordance with EEA data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting us via [email protected].
- Based on an approved certification mechanism. We will transfer your personal information to our Partner outside EEA, if our Partner is certified by an approved certification mechanism pursuant to EEA data protection legislation.
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.
- For EEA Countries,the UK and Brazil
- For US and rest of the world
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.
When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.
- for privacy questions and exercising your rights via our privacy email: [email protected];
- ur affiliate's, Outfit7 Limited, UK representative: PRIVO Verified Limited, Room 3, 168 South Street, Dorking, Surrey RH4 2ES,
- ur affiliate's, Outfit7 Limited, data protection officer: ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg;
- our Brazil data protection officer: [email protected];
- for general information please feel free to contact us via our customer service page: https://outfit7neo.com/contact/.