This
Privacy Notice explains who we are, how we collect, share and use
personal information about you, and how you can exercise your privacy
rights. The Services are governed also by the Terms of Service.
We
are iExtend Games, maker of Tuk Tuk Driving, Blue Whale, Drift Car Simulators and many more. For
details about how to contact us, see "How To Contact Us" section below.
This
Privacy Notice applies to personal information that we collect through
our games, mobile applications and other products.
1. WHAT PERSONAL INFORMATION DOES iEXTEND GAMES COLLECT?
The personal information that we may collect about you through the Services broadly falls into the following categories:
1.1. Information that you provide voluntarily
Certain
parts of our Services may ask you to provide personal information
voluntarily. For example we will ask for certain information in order
for you to register for an account with us, to begin playing Games, to
subscribe to marketing communications from us, and/or to submit
enquiries to us, such as:
The
personal information that you are asked to provide, and the reasons why
you are asked to provide it, we will try to explain to you at the point
we ask you to provide your personal information.
1.2 Information that we collect automatically
When
you use our Services, we may also collect certain information
automatically from you and/or your device which may be considered
personal information under applicable data protection laws, such as:
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. 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), as explained further
under the heading “Cookies and similar tracking technology” below.
1.3 Information we obtain from third party sources
(a)
Information from social media platforms. You may choose to connect to
our Services via your social media account. Exactly what information we
receive from your social media will depend on your social media privacy
settings, but it would typically include your basic public profile
information such as:
Typical
use cases include your game progress being connected to multiple
devices you may own and you can play the same progress using multiple
devices. In addition, we may show your Facebook friends in Game and show
your public Facebook profile name and profile picture in Game
leaderboards and in your Game profile.
(b) Third party service
providers. We may receive personal information about you from third
party sources. We may get your personal information for example when you
installed our Game and prior to installing you have clicked an
advertisement for the same Game (see Third party data controllers and
processors).
(c) Advertising partners. From time to time, we may also
receive personal information about you from other third party sources.
For example, if you clicked on an advertisement to direct you to one of
our Services (such as an advert of one of our Games in other publishers
game), we will be provided with information from which ad-network and
advertising campaign the install originated from (See below also
"Advertising").
1.4 No special categories of information
We
do not request or intend to collect any "special categories of
information" such as any information on health, race, religion,
political opinions or philosophical beliefs, sexual preferences or
orientation. Kindly be cautious when sharing this information about
yourself (or others) in our forums.
2. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for following purposes:
2.1 To provide and operate our Services:
2.2 To improve our Services and keep them secure:
2.3 To personalise our Services:
2.4 For promotional activities (including marketing and advertising)
2.5 Other
3. ADVERTISING
3.1
We use advertising to fund our Services and to make our games available
for free. We show third party advertising in our games and also
advertise our Services via third parties. We wanted to provide you with
more detail about how we use information for advertising, both in-game
and on other third party properties.
When you view ads on iExtend properties (like in our games)
3.2
To enable us to show in-game ads we may send your advertising ID and
IP-address to advertisers (or ad networks) to enable them to find
appropriate ads to serve to you in our games and on third party
properties. You can control and limit our use of your advertising ID in
your device settings. iExtend Games does not control which specific ads are shown
in our games (this is controlled by ad networks) but we do blacklist
certain categories of ads.
3.3. Advertising IDs are used by the ad networks with for a number of purposes including for example to:
(a) limit the number of times you see the same ad;
(b) ensure they are dealing with humans with real devices and not 'automated' bots
(c)
to serve you with advertisements likely to be relevant to you based on
your advertising ID engagement with other brands and ads, also recorded
using your advertising ID and using your general geographic area.
(d)
Other brands buy advertisement placement via an ad network or ad
exchange to advertise their products in iExtend Games. The ad network or ad
exchange acts as intermediary between the other game companies and iExtend Games.
In order for an ad network to charge the company buying the ad, clicks
from the ad and potentially installs of other developers’ applications
party apps are tracked. Views, clicks and installs from ads are measured
using Advertiser ID.
(e) Ad networks to keep track what games you have used to market you similar kind of games.
IP-address
is typically used by advertisers to broadly see the general geographic
area you are coming from for example country, state, and sometimes at
city level).
When you view iExtend Games ads on third party services
3.4 iExtend Games
also advertises its games on other apps by asking ad networks to serve
its to audiences that will be interested in them (determined using
Advertising IDs).
3.5 For these purposes the Advertising IDs are used
by the ad networks for a number of purposes (please refer to the
Privacy Notices of our advertising partners listed "Third Parties")
including for example to:
(a) measuring ad effectiveness (looking at
aggregated views, clicks and installs it generates through its
advertising in other publishers’ games);
(b) informing players that
have not been playing for a while about new content in the Game. iExtend Games
gives a list of these users in form of Advertising IDs to an ad network.
Ad network then shows these users ad about the new content.
(c) not
showing adverts for a game, a player is already playing, iExtend Games can send a
list of active players in form of Advertising IDs to an ad network. Ad
network then excludes these players from seeing the ad.
(d) Marketing
games to a group of potential players. iExtend Games provides Facebook a list of
Advertising IDs to match these with similar type of Facebook users to
whom iExtend Games could then market its games. iExtend Games does not have information how
Facebook identifies or creates profiles of similar type of users.
3.6
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).
4. COOKIES AND SIMILAR TRACKING TECHNOLOGY IN WEBSITES
The
Services may use “cookies” and other technologies such as pixel tags,
local shared objects, hardware-based device identifiers, flash cookies,
operating system-based identifiers, clear GIFs and web beacons.
Cookies:
A “cookie” is a small file stored by your device when told to do so by a
website. Typically websites place a number of different cookies on an
end-user’s device. Some of the cookies are “1st party,” from the website
itself, and others are “3rd party,” belonging to advertising and
analytics entities or social networks. Cookies are personal information.
However, iExtend Games’s cookies do not include any other personal information
and are typically used to quickly identify your device and to “remember”
your device during subsequent visits for purposes of functionality,
preferences, and website performance. You can disable cookies on your
device or set your device to alert you when cookies are being sent to
your device; however, disabling cookies may affect your ability to use
the Services.
5. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our
legal basis for collecting and using the personal information described
above will depend on the personal information concerned and the
specific context in which we collect it.
However, we will normally
collect personal information from you only (i) where we need the
personal information to perform a contract with you, (ii) where the
processing is in our legitimate interests and not overridden by your
rights, or (iii) where we have your consent to do so.
(a) Performance
of contract (under our terms of service) as legal basis for processing
is when we make the Game and Services available to you, provide customer
support, integrating Games with technology and distribution platforms
such as Apple iOS and Google Android and inform you of the service
related changes and Game progress.
(b) We process your personal data
on the basis of our legitimate interests for example when we provide you
the Game and Game events, serve interest based advertisements to you
(both in-game and on third party properties), carry out marketing, keep
our games secure, for engineering purposes, analysing the users’
behaviour across our Games, moderating chat discussion.
(c) We have
Legal obligation to process your personal data when to comply with a
legal obligation, such as the prevention of crime or fraud or to
maintain records relating to tax.
(d) If we ask you to provide
personal information to comply with a legal requirement or to perform a
contract with you, we will make this clear at the relevant time and
advise you whether the provision of your personal information is
mandatory or not (as well as of the possible consequences if you do not
provide your personal information).
If you have questions about or
need further information concerning the legal basis on which we collect
and use your personal information, please contact us using the contact details provided under the "How to Contact Us" heading below.
6. WHO DOES iEXTEND GAMES SHARE MY PERSONAL INFORMATION WITH?
We may share your personal information to the following categories of recipients:
(a)
To our group companies, third party services providers and partners who
provide data processing services to us (for example, to support the
delivery of, provide functionality on, or help to enhance the security
of our Services), or who otherwise process personal information for
purposes that are described in this Privacy Notice or notified to you
when we collect your personal information.
(b) to any competent law
enforcement body, regulatory, government agency, court or other third
party where we believe disclosure is necessary (i) as a matter of
applicable law or regulation, (ii) to exercise, establish or defend our
legal rights, or (iii) to protect your vital interests or those of any
other person;
(c) to any other person with your consent to the disclosure.
7. HOW DOES iEXTEND KEEP MY PERSONAL INFORMATION SECURE?
We
use appropriate technical and organisational measures designed to
protect the personal information that we collect and process about you.
The measures we use are designed to provide a level of security
appropriate to the risk of processing your personal information.
Specific measures we use include – e.g. encrypting your personal
information in transit and at rest.
8. INTERNATIONAL DATA TRANSFERS
Your
personal information may be transferred to, and processed in, countries
other than the country in which you are resident. These countries may
have data protection laws that are different to the laws of your
country.
Specifically, our Game servers are currently located in
Pakistan, and our group companies and third party service providers and
partners operate around the world. This means that when we collect your
personal information we may process it in any of these countries.
However, we ensure appropriate safeguards are in place so that your
personal information will remain protected in accordance with this
Privacy Notice. These include implementing the European Commission’s
Standard Contractual Clauses for transfers of personal information
between our group companies and third party service providers and
partners, which require all group companies to protect personal
information they process from the EEA in accordance with European Union
data protection law. It also includes transferring personal information
to third party service providers and partners which are certified under
the EU-US Privacy Shield.
Standard Contractual Clauses can be
provided on request. We have implemented similar appropriate safeguards
with our third party service providers and partners and further details
can be provided upon request.
9. DATA RETENTION
We
retain personal information we collect from you where we have an
ongoing legitimate business need to do so, for example, to provide you
with a Service you have requested or to comply with applicable legal,
tax or accounting requirements. We will for example periodically
de-identify unused Game accounts and we regularly review and de-identify
unnecessary personal information.
When we have no ongoing legitimate
business need to process your personal information, we will either
erase or de-identify it or, if this is not possible - for example,
because your personal information has been stored in backup archives -
then we will securely store your personal information and isolate it
from any further processing until erasure is possible
10. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
(a)
To access correct, update or request deletion of your personal
information. You may do so by contacting us using
the details at "How to Contact Us" heading below.
(b) To object to
processing of your personal information (which is processed on the
grounds of legitimate interests), ask us to restrict processing of your
personal information or request portability of your personal
information. Again you may do so by opting out of personalised offers
based on behaviour in-game, or by contacting us using the details at
"How to Contact Us" heading below.
(c) To opt-out of marketing
communications we send you at any time. You can exercise this right by
clicking on the “unsubscribe / opt-out” link in the marketing
communications we send you or by contacting us using the details at "How
to Contact Us" heading below.
(d) If we are processing your personal
information with your consent, you can withdraw your consent at any
time. Withdrawing your consent will not affect the lawfulness of any
processing we conducted prior to your withdrawal, nor will it affect
processing of your personal information conducted in reliance on lawful
processing grounds other than consent. You may do so by contacting us
using the details at "How to Contact Us" heading below.
(e) You have
the right to complain to a data protection authority about our
collection and use of your personal information. For more information,
please contact your local data protection authority.
You can control
and limit the nature of personal information that we collect and process
about you in a number of ways. For example, you can disconnect your
social media account from our games or control your social media privacy
settings to limit the information shared with us. You could also reset
your mobile advertising identifier or limit ad tracking altogether using
the settings on your phone. You could also limit or disable the use of
cookies (or similar technologies).
We will respond to all requests we
receive from individuals wishing to exercise their data protection
rights in accordance with applicable data protection laws.
11. 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.
12. UPDATES TO THIS PRIVACY POLICY
We
may update this Privacy Policy from time to time in response to
changing legal, technical or business developments. When we update our
Privacy Policy, we will take appropriate measures to inform you,
consistent with the significance of the changes we make.
13. HOW TO CONTACT US
Data controller: games@iextendlabs.com
You
can exercise your right to access personal information, request
personal information to be erased or to opt out of personalised offers
directly from our Games.
To do so, open the Settings.
This is the
preferred method of contacting us because we can more accurately
validate a request coming directly from the device and application.