PRIVACY POLICY FOR APPS

(Last update October 2023)

INTEREST-BASED ADS

We promote our Apps and services in ours and other publisher's apps and we also allow our partners to promote and advertise their goods and services in our Apps. We may share information we collect from you to our advertising partners and they can reuse such data for targeted advertising. We or our advertising partners may display interest-based, or retargeted, ads (''IBA''), but only for the device IDs that 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 may pass information we collect from you such as technical information, advertising and application usage information (for example if a device has clicked on a sports ad within our Apps, for more information please see Information And Data We Collect From You Section of this Privacy Policy to our advertising partners 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 our App 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 Facebook and they match it with your Facebook 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, interests, behaviors, connections and any other information Facebook receives or infers about users. We cooperate with several providers of IBA that are listed herein in subsection a) and in Opt-Out Section of this Privacy Policy (''Third Parties''). When allowing Third Parties to conduct IBA we adhere to the DAA Principles available here http://www.digitaladvertisingalliance.org/principles.

You have an option to opt out from sharing your information and data for the purposes of interest-based advertising at all times. When you opt out, you will not stop receiving ads, they just won't be based on topics you like, your interest, behavior, demographics, etc. You can opt out by choosing one of the following options (for more information please read the ''Opt Out'' Section of our Privacy Policy):

a) Via third party IBA provider:

If you choose to opt out by following one of the third party IBA provider's opt out mechanism, you should stop receiving interest-based and targeted ads via the selected IBA provider, but you may continue to receive interest-based or targeted ads through other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options b) and c) below.

b) Via "Do Not Track Settings" in mobile phone:

Turn on "Limit Ad Tracking" on your iOS device or "Opt Out of Interest-Based Ads" on your Android device.

c) Via our Apps:

Choose "Opt Out of IBA" within the settings of our Apps (where available).

ABOUT US AND THIS PRIVACY POLICY

As used in this Privacy Policy, "Outfit7 Neo", "we", "us" or "our", "ours" refers to Outfit7 Neo Limited, with a registered and business address at Christaki Kranou 20, 1st Floor, 4041 Limassol, Cyprus, and all of its subsidiaries.

This Privacy Policy is part of and incorporated by reference into the End User License Agreement (the "EULA") governing the use of all "Outfit7 Neo" branded software applications (the "App/s"), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the App. This Privacy Policy covers how we collect, use, disclose, transfer and store information received about you and/or information received about your computing device through your use of the Apps.

By using our Apps you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use the Applications. As described in greater detail below, we may share this information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services, content, and advertising.

**For general information please feel free to contact us via ** [email protected] ** and for privacy questions via ** [email protected] .

INFORMATION AND DATA WE COLLECT FROM YOU

1. Technical Information and Data

We collect technical data necessary for you to use our App and additional technical data that enables us to maintain and analyze the functioning of the App, to personalize the content of the App, and to display advertisements.

We automatically obtain certain information about your computing device, including:

  • IP address; Country code;
  • IDFAs, IDFVs, Advertising IDs;
  • Language; Locale (specific location where a given language is spoken);
  • Time zone, session start/stop time,
  • Network status (WiFi, etc.), browser plug-in types and versions;
  • User agent string (UA), platform, SDK version, timestamp;
  • Our apps installed;
  • Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, International Mobile Equipment Identity (IMEI) on Android, Android ID, Android Serial No);
  • Push notifications token;
  • Player identifier string (we collect player identifier string only upon your sign in to Google Play Games Services or Apple's Game Center).

In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Apps.

Older versions of our Apps may still obtain information such as UDID number and IMEI number. If you wish to prevent this, please update the App with the latest version available on App Store.

2. Advertising and Application Usage Information And Data

When you use our Apps, we may collect additional information by using device identifiers that permit identification of your device. Such information is used for advertising and analytics purposes.

The information collected includes:

  • Which advertisements are shown;
  • Length of time an advertisement is visible and the size of the advertisement;
  • Advertisement response (if any), including clicks on ads;
  • Angle of view;
  • Application usage information, (how often you use the app, for how long you use the app, the events that occur within the app, in-app location, in-app purchases you make and their value, aggregated usage, performance data, life time value of user etc.).

3. Classical Personal Information

We do not collect any personal information about you through our Apps, with the sole exception of persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address). Persistent identifiers are identifiers that do not identify you personally but may uniquely identify your device. Some legislation (such as US) may treat such information that uniquely identifies your device as personal information.

You can opt out from receiving targeted ads by choosing one of the options described in the »Opt Out«'' Section of our Privacy Policy.

When you voluntarily contact us directly, we may collect information about you that you provide us (such as your name and surname, email address). We will use such contact information only for the purpose for which you provided it to us. We will not share this information with third parties.

If you wish to delete your contact information that we received from you when you contacted us, please send an e-mail to [email protected]and your contact information will be deleted from our database.

HOW WE USE YOUR INFORMATION

1. In General

We use the information we collect about you/your device to deliver services to you and to operate our business. Such use by us and by our Partners may include:

  • Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analyzing trends in connection with usage of the Apps, administering the Apps, and customer communications.
  • Displaying advertisements : displaying third party advertisements in our Apps and showing advertisements for our Apps in other publisher's apps. Please see more in Advertising Section of this Privacy Policy.
  • Cross-promotion: cross promoting our Apps and services, meaning we may promote one of our Apps while you are playing a different App of ours.
  • Tracking and fraud prevention for advertising purposes: for some of our Apps we use third party services for tracking and fraud prevention for advertising purposes and for privacy compliance purposes. Please see more in Tracking Section of this Privacy Policy.
  • Analytics and research: understanding and analyzing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the App was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test our new game features and content. We use the data we receive from Third Party Social Network only for internal analytics.

2. Game Notifications

There are two types of notifications in our Apps - local and push notifications. Local notifications are contextual and sent from the device, whereas push notifications are sent from the server. We use such notifications to remind you about your activities within the App. You will receive such notifications only if you are subscribed to such notifications in the App. To unsubscribe, please use the instructions provided below:

  • For iOS : You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap "Notifications"; Find the App; Tap on the icon of App; Manage the "Notifications" option by sliding it OFF or ON.
  • For Android and Windows : After an App is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the "info screen" on the homepage of the App and choosing the "Settings" option. Here, push notifications can be disabled by unchecking the "Notification" option within the App.

We collect push notification tokens for us to be able to determine whether you are subscribed to push notifications. When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.

3. Survey

We are conducting surveys 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 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 limit 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 App 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 wish to opt out from conducting an in-app survey, do not click on the survey button or deny answering the survey questions.

HOW WE MAY SHARE YOUR INFORMATION TO THIRD PARTIES

We cannot provide all services necessary for the successful operation of the Apps 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 Apps (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 and our Partners' advertising campaign performance. We may share such information to:

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. 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.

For any additional questions about third party information collection please refer to [email protected].

HOW OUR PARTNERS MAY USE YOUR INFORMATION

We strive to adhere to the generally accepted industry practices regarding the collection and the usage of information by our Partners and to limit their usage to the services they provide for us. They adhere to this Privacy Policy, but in some cases we must use their privacy policies.

We strive to commit our Partners to using the information solely for the purposes as stated in this Privacy Policy. 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).

Some of the Apps allow you to submit content generated in or by the Apps to third party sites like Facebook, Vkontakte, Google Play Games, Game Center and YouTube. These submissions follow the information transfer protocols of such third parties, which are designed to enable content sharing with such third parties.

ADVERTISING

When you use our Apps we may display contextual advertisements to you. In order to enable advertising we allow our advertising partners to collect online identifiers (such as Advertising ID on Android and IDFA on iOS) that might be considered as personal information under some legislations, but they should use it solely for the purposes of contextual advertising. For any other purposes they should use the information solely on anonymized and aggregated basis.

For some territories, we may use and share with our advertising partners technical and advertising and application usage information we collect from you (please see Information and Data We Collect From You Section of this Privacy Policy) in order to enable our advertising partner to deliver, target and optimize third party advertising in our Apps, so that the advertisements you see are more relevant to you and are based on your app and device usage, online behavior and interests (this is commonly referred to as online behavioral or interest based advertising, i.e. IBA). In addition, we may use and share such information with our advertising partners to target and optimize our advertising and promotions in our and other publisher's apps.

We will always follow applicable legislation and accepted market practices, thus we will not use and share information for the purposes of behavioral advertising for users who did not pass the age gate in our Apps and for those who opted-out of IBA. For more information on behavioral advertising and our IBA providers please see Interest-Based Ads Section of this Privacy Policy. For opting out from sharing your information and data for the purposes of behavioral advertising please visit Opt-Out Section of this Privacy Policy.

TRACKING

When you use the App, we or third parties operating the advertisement serving technology may use information logged from your device using SDKs, cookies, web beacons and other technologies to ensure that appropriate advertising is presented within the App and to calculate the number of unique and repeat views of advertising.

For some of our Apps we use third party tracking and data collection tools from our service providers for the purposes of tracking performance, ad visibility and privacy compliance of third party SDKs in our Apps.

We use third party tracking and data collection tools from our service providers, such as AppsFlyer, for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes. Such tools may use cookies, APIs, and SDKs in our Apps to enable them to collect and analyze user and device related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-app events.

In addition, our Partners may use their own tracking technologies (including and without limitation: SDKs, cookies, Web beacons, HTTP cache, local shared objects and other technologies) in order to track impressions, clicks, installs or other advertising campaign performance indicators for the purposes of measuring third party advertising campaign performance.

THIRD PARTY SOCIAL NETWORKS

1. Connecting to Third Party Social Networks

Some of our Apps use third parties' services such as Google Play Games Service, Apple Game Center, Facebook, YouTube, Twitter or Vkontakte ("Third Party Social Network/s"). Such Apps enable you log in to your Third Party Social Network account to connect to our App by using the "Log in with" or "Connect to" feature in our App. You may also share the content you created within the App on Third Party Social Networks. By logging in to your Third Party Social Network account to connect to our App or by using the App to share content on such Third Party Social Network, you are authorizing us to collect, store, and use any and all information, in accordance with this Privacy Policy, that you agreed that such Third Party Social Network could provide to us through the Application Programming Interfaces ("API"). You authorize us to do so when you "accept" or "allow" (or similar terms) connection of one of our Apps to such Third Party Social Network. The information you allow us to access varies by App, and it is affected by the privacy settings you and your friends establish on those Third Party Social Networks. You can control and find out more about these settings at the Third Party Social Network in question. Please note, Third Party Social Networks are governed by their own privacy policies, terms and end user agreements and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate those sites. For additional questions you can contact us at [email protected].

2. Data We May Access Via Third Party Social Networks

If you use the "Log in with" or "Connect to" feature 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 public profile, such as your name, surname, profile picture, age range, gender, and other public information; (ii) email address, login ID and/or player identifier string (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the "Log in with" or "Connect to" process. We may share your name, profile picture and your game data (such as moves, App progress and scores) with respect to the applicable App, with your friends who have also used the "Log in with" or "Connect to" feature in connection with such App or with your contacts in applicable Third Party Social Media Network account.

The App may further ask you to allow us to post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates). Please keep in mind that we will only do that if specifically allowed 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 App on your device so that the App will be able to communicate with Third Party Social Network directly; Voice recordings from Apps are also only being collected and stored within the Apps solely upon your request.

3. Consent to Publicly Display Data on Third Party Social Networks

If you use Third Party Social Networks to participate in game related activities, including but not limited to participation in leader boards, multi-player games or the downloading and uploading of content, Outfit7 Neo and its affiliates may also collect, use, store, transmit and publicly display statistical data regarding game play (including scores, rankings and achievements), or identify content that is created and shared by you with other players. Data that personally identifies you is collected, used, stored and transmitted in accordance with this Privacy Policy.

THIRD PARTY TERMS AND CONDITIONS

Please note that your access to and ability to use and interact with the Apps 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 Outfit7 Neo is not liable for any such third party terms and conditions and their use of your personal information.

Our Apps may contain links to third party websites, products, or services. For example, the Apps 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.

CHILDREN'S PRIVACY

We do not knowingly collect personal information from children under the age of digital consent according to the applicable legislation. If we learn that we have collected personal information, 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].

OPT-OUT

You are always free to opt out from the future collection of your personal information by Outfit7 Neo in accordance with this Privacy Policy by uninstalling all the Apps from each of your computing devices.

Opting Out of IBA:

  1. Via third party IBA providers

For Outfit7 Limited please visit https://outfit7.com/privacy/en/#iba.

If you choose to opt out by following one of the third party IBA provider's opt out mechanisms, you should stop receiving ads based on your interest via the selected third party IBA provider, but you may continue to receive interest-based or targeted ads via other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options 2. and 3. below.

  1. Via "Do Not Track Settings" in mobile phone

If you choose to opt out via "Do Not Track Settings" in your mobile phone all providers of advertising services are bound to comply with such "Do Not Track" setting, 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 advertising ID with advertisers for the purposes of IBA. 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.

i** OS DEVICE**

  • iOS 7 or Higher

Go to your Settings > Select Privacy > Select Advertising > Enable the "Limit Ad Tracking" setting

  • iOS 6

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

ANDROID DEVICE

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"

  1. Via our apps

We have created 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.

IN-APP PURCHASES

Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the app store via your app store account. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store.

For more information on in-app purchases in our Apps please see In-App Purchases Section of the End User License Agreement available at https://outfit7neo.com/eula.

PROTECTION OF PERSONAL INFORMATION

We have implemented: reasonable security measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

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

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 regarding your personal information may be submitted to [email protected]. For some of our Apps we may develop in-app deletion request functionality which can be used in addition to the address above.

INTERNATIONAL TRANSFER

We operate globally, thus we may for the purposes described in this Privacy Policy transfer your information to our affiliated entities and/or to other third party service providers across border and from your country or jurisdiction to other countries or jurisdictions around the world. Please note, that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, 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.

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 unless a longer retention period is required or permitted by applicable legislation.

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.

CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at https://outfit7neo.com/privacy.

Should you request so by informing us on [email protected], we will send you all the updates of this Privacy Policy to your e-mail. We will also inform you about any material updates of our Privacy Policy with an in-app banner and a link.

PRIVACY QUESTIONS

If you have questions or concerns about Outfit7 Neo's Privacy Policy or information processing, please contact us through [email protected].

Outfit7 Neo Privacy Policy, v.1.0, updated October 19, 2023