PRIVACY POLICY

AppGem, alongside its subsidiaries and affiliates, is a company that develops, publishes, and operates social games for web and mobile platforms. This includes creating and managing various applications and games that can be played across multiple devices and platforms, such as mobile devices and Google. Together with the games and applications, these are all part of what AppGem calls its "Services."

AppGem prioritizes the privacy of its users and aims to be transparent and fair in how it handles user data. Their Privacy Policy outlines the ways in which they collect, store, use, and share personal data of those who use their Services. This policy applies to anyone who visits their websites, installs their applications, plays their games, interacts with the company in any way, or uses their Services in general.

The company advises all users to read the Privacy Policy carefully to fully understand and agree to its terms before using the Services. AppGem emphasizes that if a user does not agree with the policy, they should not use the Services. The policy also states that users can choose to stop using the Services at any time.

As a "data controller," AppGem is responsible for how it handles and uses personal data about its users. They are obliged by certain data protection laws to inform users about the details contained in the Privacy Policy. While users are not legally obligated to provide personal data to AppGem, the absence of such data may limit the full range or the optimal experience of the Services offered. For example, users can play games without connecting their Facebook account but would miss out on the social features of those games.

1.  DATA COLLECTION

We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):

a. Data automatically collected or generated:

AppGem collects technical and usage data through interactions with their services and communications, utilizing cookies and tracking technologies. This includes information like IP addresses, in-game activities, device specifics, and user behavior, aimed at understanding user engagement and optimizing advertisements and content. This data, while not used to identify individuals directly, enhances user experience and service performance. For details on advertising practices, refer to their policy's Section 7.

b. Data received from you:

AppGem allows users to voluntarily provide personal data in various ways, including setting up accounts, contacting through different channels, participating in forums, signing up for updates, engaging in competitions, making purchases, interacting with other users, and connecting accounts from platforms like Facebook, Google, or Apple to their games. This personal data helps enhance user experience and service offerings.

c. Data received from Google and other channels:

When you connect your game account to platforms like Facebook, Google, or Apple, AppGem accesses your public profile details, including your name, email, gender, and friends list, to enhance in-game social features. They also gather data on advertising effectiveness, such as target demographics. It's recommended to review the privacy policies of any third-party platforms you use in conjunction with AppGem's services to understand the shared information fully. For more on their advertising methods, see their policy's Section 7.

d. Transaction Data:

AppGem doesn't store your financial details like credit card numbers for in-game purchases; those are handled by the platform provider (Apple, Google, Facebook). However, they do receive non-financial personal data such as your name, billing address, and purchase details for transaction fulfillment and accounting.

2.  DATA USES

We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):

a. Performance of a contract:

We will use this basis for processing necessary to make the Games, including social gaming when you choose to log in with Facebook, Google or Apple, and support services, available to you, and to send you service communications, gifts and awards

b. Consent:

In limited cases where you choose to sign up to receive direct marketing emails, where you accept cookies on our Sites, we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details in Section 8.

c. Legitimate interests:

Legitimate interests. We will process your Personal Data based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Games and through other channels, matching users to create in-game friends lists, improving our customer service and support operations, fraud detection and protecting and securing our users, ourselves and our Services.

d. Compliance with legal obligations:

Compliance with a legal obligation. In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.

The purposes for which we use Personal Data are described in more detail below:

1. To facilitate, operate, and provide our Services
2. To authenticate the identity of our players, and allow them access to additional features
3. To provide our users with customer care, assistance, and technical support services.
4. To enable you to interact with other players in the game
5. To enable you to identify other players in the game who are listed in your phone "contacts," provided that you have authorized upload of your contacts for that purpose;
6. To further develop, customize, and improve the Services and your user experience, based on common or personal preferences, experiences, and difficulties, including by personalizing your profile and friends list;
7. To manage and deliver advertisements more effectively, including contextual, behavioral, and interests-based advertising based on in-Games progress and activity, based on your preferences or other data available to us or to our Service Providers, including for re-targeting purposes
8. To contact our users (via e-mail, Facebook, push notifications or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as Games updates, bonuses, new features, VIP services, etc.); and to facilitate, sponsor, and offer certain events and promotions
9. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error, or any illegal or prohibited activity
10. To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our Service Providers may use to provide and improve our respective services
11. To comply with any applicable laws and regulations.

3.  STORAGE AND RETENTION

AppGem commits to handling your Personal Data securely and lawfully, aligning with common industry standards, regardless of the potentially less stringent legal requirements in the jurisdictions of its affiliates and Service Providers.

The primary reason we hold onto your Personal Data is to maintain our user relationship and deliver our Services to you. We'll keep your information only as long as necessary for the purposes we collected it for, meaning until you're actively using our services or until you inform us you'd like us to do otherwise. If you decide to delete your account, we will take appropriate steps to remove your Personal Data. However, we may keep your Personal Data for legal and accounting reasons, such as compliance with record-keeping laws and to have evidence of our relationship if legal issues arise post your discontinuation of our Services, all in line with our Data Retention Policy. For inquiries about this policy, you're encouraged to reach out to us via our contact page.

It's important to note that we're not bound to keep your data for any fixed period unless specifically mandated by law. We can securely dispose of your data at any time, for any reason, with or without prior notice to you.

Under certain conditions, we might anonymize your data, rendering it unable to identify you. Once anonymized, this data is no longer considered Personal Data under this policy, and we may use it without further obligations to you.

4.  PERSONAL DATA DELETION AND CLOSURE OF ACCOUNTS

AppGem provides you with the right, as detailed in this Privacy Policy (except where noted in the Candidate Privacy Addendum), to request the deletion of your Personal Data. You can do this at any point by using the "Account Deletion" feature available within the relevant game (this only applies for games that support Google/Facebook/Apple login), and following the provided instructions. Opting for this will close your account and erase all related data, including your play history, purchases, social media connections, and any other data linked to you in the game. Remember, this action is permanent. If you have accounts in more than one game, you'll need to individually request account closures for each.

Once we receive your deletion request, we'll act on it swiftly, though some time may be needed to fully process your request. It's also important to note that we might keep a copy of your Personal Data if we're legally obliged to do so.

5.  DATA SECURITY

AppGem takes the protection of your Personal Data seriously, implementing suitable physical, procedural, and electronic safeguards, including encryption when necessary, to secure the data held by us and our Service Providers. Despite these efforts, it's important to understand that no security measures are infallible, and we cannot assure total security of Personal Data stored either by us or with third-party services. If you identify any security weaknesses or vulnerabilities in our Services, you're encouraged to report them by emailing [email protected].

6.  COOKIES AND TRACKING TECHNOLOGIES

Our Services and some of our Service Providers utilize "cookies", anonymous identifiers and other tracking technologies (collectively, "Tracking Technologies") which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Games and Services as a whole.

7.  ADVERTISING

Our games feature ads for third-party services and products. To enhance advertising effectiveness and relevance, we and our advertising partners utilize certain data about you, including deploying interest-based ads and employing targeting, ad measurement, and attribution technologies. This data may include device advertising identifiers (like IDFA or Advertising ID), details from your Facebook, Google, or Apple profiles (e.g., gender, region), gameplay information, user in-game ID, product interaction data, and demographic and interest-based information, obtained either with your consent or on another legal basis.

Advertisements from us or our partners can appear within our games, our other services, or on external channels, including websites and apps not owned by us. Our Privacy Policy does not cover the practices of third parties we don't own or control, or those outside our management. Information you provide to third-party sites or services advertised through our Services is governed by their privacy policies, so we recommend reading them carefully. We are not responsible for the protection of information you give to third parties.

To adjust your preferences for interest-based advertising, you can modify your device's settings to either reset your advertising ID or opt out of such advertising, typically found under the "Privacy" or "Ads" settings. For those in the USA, Canada, or Europe, opting out from data collection by advertising partners participating in the Digital Advertising Alliance is possible through designated websites.

Resetting your advertising ID or opting out of interest-based advertising means you'll still see ads, but they won't be tailored using your device’s advertising ID. Ads might then be based on context like your game progress or language preferences, which could affect your user experience.

We use Google Analytics and may use other analytics tools, governed by their own privacy policies. Google uses cookies and SDKs for tracking and ad serving in our games. For more about Google's data handling, see their privacy documentation and opt-out options.

8.  CONTACT US

If you have any questions about these Terms and Conditions, You can contact us:

• By email: [email protected]

Last updated: March 26th, 2024