Zinky Games Privacy Policy

PRIVACY NOTICE

Last update: June, 2022

For your convenience, we have provided a translated version of our Privacy Notice. Unless otherwise specified and to the extent permissible under applicable law, the English version will control.

INFORMATION WE COLLECT
We collect (a) personal data that you actively submit to us as a user, (b) personal data we automatically collect through your use of the Services, (c) non-personal data we automatically collect through your use of the Services, and (d) personal data received from third parties.

(a) Personal Data You Actively Submit to Us as a User

We collect your Player Name if you create one to access certain in-game features. We collect your email address at the time you create a Zinky ID Account. We collect your Apple Game Center ID and/or Google Play Gamer ID at the time you link an ID to your Zinky ID Account.

(b) Personal Data We Automatically Collect through Your Use of the Services

We collect online and mobile device identifiers when you access the Services, usually when you download and play one of our mobile applications or when you browse or interact with one of our websites. The type of identifier collected depends upon the device and technologies you are using to access the Services and include:

IP address – Internet Protocol address used by computing devices such as personal computers, tablets and smartphones;
MAC address – Media Access Control address assigned to a network interface controller;
IDFA – Apple Device Advertising Identifier;
GAID – Google Play/Android Device Advertising Identifier;
GUID – Globally Unique Identifier, which is the reference used in relation to Microsoft technologies;
UUID – Universally Unique Identifier, which is the reference used in relation to technologies other than Microsoft technologies.
The mobile device identifier IDFA is not collected if you have limited Ad Tracking on your device. Resetting your Ad Tracking setting will change collection of this data. Likewise, the mobile device identifier GAID is not collected if you have opted out of Ads Personalization on your device. Resetting your Ad Personalization setting will change collection of this data.

We collect non-personal device information, account information, and gameplay data automatically generated or collected through the Services including:

General language & region setting (we don’t ask for or track precise location based information from your device);
Technical information such as app version, device type (hardware), OS or operating system (software) and OS type, browser and domain so we can serve you with the most relevant game content and optimize app performance for your device; and
Game progress such as features used, in-game events, interaction with other players and purchases in order to maintain progress in your account and analyze aggregated game data to improve the game.

(d) Personal Data Received from Third Parties.

From time to time third-party advertising partners also provide us IDFA/GAID information from your device. This is to help us measure the effectiveness of our ad campaigns where we advertise our games on other third-party platforms and services. For example, when you click on an ad that directs you to install a Zinky game, we receive the IDFA/GAID to know the ad network and campaign source.
-Advertising
Adjust (Adjust GmbH)
Adjust is an advertising service provided by Adjust GmbH.
Personal Data processed: Tracker; Usage Data.

Unity Ads (Unity Technologies ApS)
Unity Ads is an advertising service provided by Unity Technologies ApS.
Personal Data processed: Tracker; Usage Data.

-Analytics
Google Analytics for Firebase (Google LLC)
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.

GameAnalytics (GameAnalytics ApS)
GameAnalytics is an analytics service provided by GameAnalytics ApS.
Personal Data processed: Tracker; Usage Data.

We use cookies and other similar technologies to collect certain technical and usage information. For more information regarding our data collection using these technologies, please see our Cookie Notice.

HOW WE USE COLLECTED INFORMATION
We collect, process, and use the information we collect for the following purposes:

-To provide you with access to the Services (including the social features of our games like in-game chat, messages, and alliances);
-To personalize your gameplay experience;
-To improve our games;
-To host related game web forums;
-To provide you personalized offers related to ‘purchase’ features of the game,
-To administer your account (including ensuring compliance with the Terms of Service);
-To provide you with technical support when requested;
-To notify you of new updates, features, enhancements, products and services,;
-To communicate with you about events, forums, game features, promotions and purchase opportunities;
-To notify you of changes to our Privacy Notice, Cookie Notice and/or Terms of Service; and
-As we, in our sole discretion, otherwise determine to be necessary to comply with applicable law or required to ensure the safety and/or integrity of our players, users, employees, third parties, members of the public, or Services.

We process your personal data as described above according to one or more of the following lawful bases, depending on each specific context and the types of personal information concerned:

-Processing as necessary to establish and fulfill a contract with you. For example, where you download and play our game that are subject to our Terms of Service and we provide our Services, administer your access to our Services, improve our games, analyze gameplay, communicate with you for transactional purposes, and provide customer support services;
-Processing in our legitimate interests (not superceded by your rights) for purposes that can be reasonably expected within the context of your use of our Services. For example, performing analytics to improve Services performance, monitoring in-game activities to prevent fraud, misuse of our Services and Terms of Service violations, and delivering in-game contextual advertising where applicable;
-Processing as necessary to comply with legal obligations. For example, maintaining accurate business records for tax and financial reporting or to respond to valid legal requests.
-Where we have your consent to use your personal information for marketing purposes.

HOW YOUR PERSONAL DATA IS SHARED
We share your personal data with the following types of recipients:

-Zinky affiliates in order to access the shared services available amongst the Zinky entities.
-Third-party service providers. We work with third-party service providers to support us in making the Services available to you. These are services like cloud hosting, analytics or other technical tools, and player support services. These service providers only process your data as directed by us for the purpose of supporting and servicing the Zinky games that you are playing. We do not sell your personal information to third parties.
-Competent law enforcement or regulatory authorities, government agencies, courts of law or other third parties. We may disclose your data or information about you in response to a request where we believe in good faith that we are under legal obligation, or legally permitted, to do so; or where we believe it is necessary:
-to detect, prevent, and address fraud, violations of our terms or policies, or other harmful or illegal activity;
-to protect ourselves such as establishing, exercising, or defending our legal rights (including our intellectual property rights and those of our licensors); or
-to protect your vital interests or those of any other persons such as public safety.
-Third parties in connection with a business transfer such as a merger or acquisition of any part of Zinky’s business, or a sale of all or a portion of Zinky’s assets to another company.

NOTICE REGARDING PUBLIC POSTING AREAS
Please be mindful that any information you include in a message you post to any public posting area is available to anyone with Internet access. PLEASE BE EXTREMELY CAREFUL WHEN YOU DISCLOSE ANY INFORMATION IN PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN THESE PUBLIC POSTING AREAS. For example, if you do not want people to know your email address, do not include it in any message you post publicly.

DATA SECURITY
We use technical and organizational measures to protect the personal data that we hold against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed. The practical reality is, however, no data transmissions over the Internet can be guaranteed to be 100% secure. Therefore, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a data breach that is likely to affect the security of your personal data, we may attempt to notify you electronically via email so that you can take appropriate protective steps and/or by posting a notice via the Services if a data breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

DATA RETENTION
We retain your personal data for a reasonable period of time to fulfill the processing purposes outlined above. For example, your personal data, such as your Player Name and Email Address, are retained as part of your Zinky ID Account information as long as your Zinky ID Account is active so we can provide you with access to the Services. As another example, your personal data may be retained to fulfill our legitimate interests such as resolving disputes or enforcing our Terms of Service or other policies, or as necessitated by law or legal considerations, such as for tax, auditing, fraud detection, maintain marketing suppression lists of transactional history. When retention is necessary, we will de-identify such personal data to the extent reasonably possible. When retention is no longer needed to fulfill the processing purposes, your personal data is deleted from our records.

The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

Zinky Games Inc.
info@zinkygames.com