Zillion Whales Limited Privacy Policy

 

  1. Who we are and what this document is about
    1. We are Zillion Whales Limited, a British company, located at 1 Princeton Mews, 167-169 London Road, Kingston upon Thames, Surrey, KT2 6PT, United Kingdom of Great Britain and Northern Ireland (hereinafter “Zillion Whales”).
    2. The controller of the personal information collected is Zillion Whales.
    3. This Privacy Policy is a document that explains what kind of your personal data we use, how exactly do we use it, for what reasons do we need your personal data and what rights do you have concerning your personal data. 
    4. This document is obligatory for both you and us. You cannot use our products or services if you do not agree the Privacy Policy. In addition, we cannot use your personal data by any way, that contradicts the Privacy Policy or by the way, for that you have not given us your consent.
    5. We believe that you when you wish to use our products:

 

  1. What information do we collect
    1. The information we collect depends on what products you use and how you use them. 

 

  1. Information You Give Us Directly

Data you provide for registering like your nickname that you choose on your own.

Please, note, that we do not create an account with a lot of settings and personal information; we just identify you with your game progress by your nickname and ID of your device. Our products do not have any “account” as it is always understandable. 

 

  1. Other Information We Collect When You Use Our Products

This type of information we collect automatically when you use our products, including:

We also receive this information when you view content on, or otherwise interact with, our services or products, which we refer to as Log Data, even if you have not registered. This Log Data includes information such as your IP address, operating system, screens visited, location, device information (including device and application IDs), and cookie information. We use Log Data to operate our products and to ensure their secure, reliable, and robust performance. For example, we use Log Data to determine what features are popular on our services. We also use this data to improve the content we show you and to identify potential misuse of our products.

 

  1. Information Provided to Us by Third Parties

By signing up to play our products on the following computer entertainment systems, consoles or mobile devices operating under iOS or Android, you agree your Sony Entertainment Network, Microsoft, Valve Corporation, Google or Apple Inc. account information will be provided to us:

PlayStation®3 & PlayStation®4 Computer Entertainment Systems

Xbox Live

Nintendo Switch™

Apple TV

Steam

Mobile Platforms App Stores (Google Play, App Store) 

 

We receive information including your name or nickname, email address, Online or device ID, your country, state or province, language and date of birth. We do not receive your credit card number or other financial information or any sensitive information.

 

Other Third Parties

We may receive information from third parties, like Facebook or Game Center, when you use these services in connection with our products (for example, if you wish to register with your Facebook account). 

We may also receive information about you when other players choose to share their contact lists. When you log in with a social network account, you may have the option of sharing information such as the name you use on that network and your friends list or other information that the third party social network chooses to share.

 

  1. How Do We Collect Information
    1. We collect some information from you when you provide it to us directly, such as when you are registered or for example, login with your Facebook account, or when you make a request to our support team. 
    2. Third parties and we also use certain technologies to collect information to improve our products and your choice, such as:

 

  1. Cookies and Similar Technologies

We do not use “classical” browser cookies, but we use Analytics and Advertising technologies in our products that utilize the cookies - pieces of data and technologies that help to identify you and your devices, which in turn can help personalize an experience, including the ads that are displayed, prevent fraud, and store preferences. These technologies are described below. 

  1. B.Analytics Technologies

We use our own game servers and internal and third party analytic technologies to collect information about how you use our products, your device and the health of our products.

We may collect and store data from your device when you use our products. This information includes technical and related information about your device and operating system (such as IP Address and device ID), information about gameplay and usage statistics, system interactions and peripheral hardware. If you play a game offline, this data will be stored on your device and transmitted when your device connects to the Internet. 

Analytic technologies also can report us in following events: onboarding events (what is your first interaction with the game, when you have start or complete a tutorial, etc.), progression (start and finish of a game level, fail out of a level, etc.), application (for example, what screens do you see and how often), monetization (do you buy something inside the game, value and details of purchases), engagement (your completed achievements, levels, etc.).

 

  1. Ad Serving Technologies

These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to identifiers, this information includes so-called in-app events and advertising opt-out signals:

Ad Serving Technologies and Analytics Technologies companies collect and use information under their own privacy policies. A representative list of third party companies that operate in our products and links to their privacy policy are:

https://unity3d.com/ru/legal/privacy-policy

https://unity3d.com/ru/legal/cookie-policy#cookies

https://amplitude.com/privacy

https://www.appsflyer.com/privacy-policy/

https://answers.chartboost.com/en-us/articles/200780269

 

  1. Bug reports

Our software can automatically generate and submit to us bug reports upon a crash or other fault that may include information about other software or hardware on a user's system. We do not associate and store the automatically generated bug report information with your personally identifiable information. Any bug reporting information you manually submit is associated and stored with personally identifiable information voluntarily by the user through a bug report.

 

 

  1. How We Use Your Information
    1. We use your personal and non-personal information, both individually and combined together, in the following ways by collecting it, recording into our servers, structuring, sharing or even erasing or destructing it:

Information Collected 

Purpose 

Data you provide for registering in products 

We use this information in order to manage and administer the services and products provided to you, to keep your “belongings” inside the application safe and to associate your game progress and all in-game transactions with you, activate or authenticate your games and save game progress and stats.

We also use this data to enable us to fulfill our obligations to you as part of the services and products (e.g. in cases where you request restoration of your account) and to facilitate your gameplay on multiple devices when available.

Additional data received when you access the products, including information regarding technical devices, technical interaction with the products such as your IP-address, time of registration, device ID, country and language settings, device model and operating system, your installed apps, screen resolution, and your in-app behaviour.

We use this data for internal review in order to constantly improve the content of our products, operate, improve and develop them, optimizing your user experience, to identify, fix, and troubleshoot bugs and errors, improve the quality and design of our products, and to notify you of changes to the products.
We also use this information in order to improve the adverts and measure the effectiveness of these advertisements.

As part of maintaining and administrating our products, we may use the information to analyse your activity and ensure that rules and terms of use of our products are not violated.

Information that is created by you while placing requests to our support team.

We use this information in order to verify your identity and to fulfil your support request. To provide you support, including to help identify and troubleshoot problems with your account or games; to survey your opinions through surveys or questionnaires; communicate with you and respond to your specific requests or questions; and manage and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties.

We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service. 

Information that is received as the result of your behavioural actions when using products (including your game actions and achievements, badges). 

This information can be available to other users of our products (e.g. on leader boards).

We use this information in order to manage and administer products including providing products to you, to operate, improve, and develop our games and services.

We may also use this data in order to tailor and improve the adverts that are presented to you to and measure the effectiveness of these advertisements, personalize advertising for you and deliver targeted marketing, service updates and promotional offers.

We also could use it to set up loyalty programs.

Data collected via third parties, including your social network ids, application store ids, nickname, when you register via you social or application store accounts and/or connect your social account to our products.

We use this information in order to manage and administer the products provided to you; to facilitate sharing on social networks.

We use this information for certain social functions of our products.
We also use this information in order to provide you with updates and information on our and selected third parties' products and services we think you may be interested in.

If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

 

  1. Data sharing
    1. Your nickname can be available to other users of our products. 
    2. If you participate in public tournaments, we may publish you data as part of the tournament score tables on our and third party web sites.

 

    1. Third party service providers 
      1. 5.3.1.Sometimes we may also need to share your data with a third party in order to provide our services or products to you or to administer them, for example if you choose to share your data across other social media platforms. We may share your data with our third party contractors and application developers provided these third parties assume confidentiality obligations regarding your personal data collected by your use of the applications they offer.  
      2. 5.3.2.The information shared with these third parties may be used, among other things, for industry analysis, tracking ad conversions or demographic profiling. 
      3. 5.3.3.Our advertising and analyzation systems are designed so that your information will not be shared directly with our third parties. 

We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leader boards or to show trends about use of our products.  We do not share personal information that directly identifies you (such as your name, e-mail or postal address) with independent third parties without your consent.

      1. 5.3.4.The information that is analysed with use of Unity Analytics or Amplitude is non-personally identifiable information regarding your behaviour and usage patterns of our products. That means, that we are not telling them about your personal fails and achievements in our games, they can even do not know your nickname, but with help of analyzation systems, we can see, that, for example, level 4 is too complicated for our players and only one player of 100 can finish it on the first try. But it does not matter for us who this one player or those 99 players are, as we analyse the game, not the history of your personal fails or success.

As for the advertising that AppsFlyer, Chartboost or UnityAds may show to you, they also do not know who you exactly are. Your behavior is interesting for them; may be, the type of device – to propose you different accessorizes for you mobile phone, and all other things that make you target audience for advertising, but the name or contact details does not make any influence on what advertising you can be a target. That is why we do not give them the information, who you are. As for us, if you do not choose to login with your Facebook or GameCenter account, we also do not even know what is your name. For us, you are not an identified person that means that we can identify you by some other identifiers, but we do not know exactly. 

Please, note that AppsFlyer, Chartboost or UnityAds will also learn about your devices to optimize their advertising campaigns, including to frequency cap and deliver targeted ads.

      1. 5.3.5.We may modify other information that can identify you or your device to limit or prevent such identification by de-identifying it or aggregating it. We can share de-identified and/or aggregated information to any third party without restriction and use it for any purpose.
    1. We will share you information with the government or law enforcement officials or private parties if we believe it is necessary or appropriate to respond to claims and legal process, to satisfy any applicable laws or regulations, to protect our property and rights or any third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable or that poses a threat to the safety of you, another person or the public generally; if we believe that our products are being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
    2. However, in the event of a merger, acquisition or any other reorganizations of our company, transfer of control, sale of all or a portion of its assets, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.
    3. We do not control information sent from your device to third parties, such as advertising networks and analytics companies that receive information in the normal course of your activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our products. An example is the Facebook "Like" button.
    4. We may share your information for other purposes if (i) you direct us to do so or (ii) you consent to such sharing.
    5. Finally, we may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.

 

  1. Where We Hold Your Information

Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in any country in which we operate. By using our products, you consent that your personal information may be transferred, stored and processed by recipients in various countries around the world where our servers are located and our databases are operated that may have different levels of privacy protection than your country. 

We may transfer and maintain your on our servers or databases some of your personal information outside the European Economic Area (EEA).

 

  1. How We Protect Your Personal Information

We employ a variety of measures to safeguard the collection, transmission and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Even so, no security measure is 100% perfect. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control.

 

  1. Your Choices About Collection and Use of Your Information
    1. For you not to read all these laws and directives that are not a very pleasant reading, we would like resume, that among other, you have the following rights in relation to your personal information:

 

Before we process any request, we may ask you for certain information in order to verify your identity. Where permitted by local law, we may reject requests that are unreasonable or impractical. 

We will respond to your requests in a reasonable timeframe.

    1. Please, note that there are extra-options for opt-out for the third parties whose advertising and analyzation systems we use in our products: for example, at https://www.appsflyer.com/optout you can using your device identifier(s) remove all usage tracking from apps that use AppsFlyer Services and they will stop tracking data for that device going forward. The services will stop across all applications, not only ours.

You may also opt-out of interest-based advertisements by adjusting the settings on your mobile device. For iOS mobile devices, go to “Settings” from the device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on the device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.”

To learn more about targeted or interest based advertising and to opt out of certain targeting program, you may also click below for the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”) opt-outs: 

http://www.networkadvertising.org/choices

http://www.aboutads.info/choices/. 

We do not control these third-party provided opt-out processes and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

 

  1. Retention Periods

We may keep information that how do we think we may need to resolve any disputes, enforce our agreements with you and provide you possibility to use our products, protect our or your legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our products. 

Otherwise, we will retain information about you for as long as reasonably necessary to provide you products, create and improve our products, comply with the law, and to run our business. 

For example, as we use your nickname and device ID to restore your access to our games, we will keep this information as long as it possible to always give you the possibility to come back in our game even 10 years after you used to play it for a last time (we are very ambitious and we hope that our game products will be long-livers and not only this generation of players will know about them and love to play it). Therefore, this information will be kept forever or as long as our games or we ourselves exist or till the moment, you ask us to delete them. 

 

  1. Children

Protecting children's privacy is extremely important. Our products are intended for general audiences and do not knowingly collect or process any personal information from or with respect to children under 16.  Through our products, children will be able to receive local in-app notifications, which do not collect any personal information.

As we do not ask your name and your exact age, we hope that you will identify yourself as being children (i.e. under the age of 16 or under the minimum age in the relevant territory). By our side, we will: (1) not ask children to input their personal information, (2) collect certain information for limited purposes only (consistent with applicable law), (3) block or restrict the child from accessing relevant services, if applicable; and/or (4) obtain consent from parents for the collection, use, and sharing of their children's personal information, if we will need this information.

If you are a parent or legal guardian and you wish to revoke your previously provided consent, review information collected from your child or have that information deleted, or you believe that your child under the age of 16 has submitted his or her personal data or other data without your consent, permission, or authorization, please, let us know immediately, and we will delete data, stop using such data and inform any other party we suspect to have access to such data to do the same.

If we make any material changes to how we use, collect, or share your child's personal information, we will notify you by in-game notice in order to obtain verifiable parental consent for the new uses of your child's personal information.

 

  1. Third Party Services

Our products may contain advertising or links to third party services (such as the Facebook Like button or links to third-party websites). If you click on those links, including an advertisement, you will leave our product and go to the site you selected. As we do not operate those sites, applications and services, we cannot take responsibility for the privacy practices of the entities that operate them. We recommend that you consistently check privacy policies of every site or service. As a reminder, this policy concerns only our products. 

 

  1. Changes to Our Policy

We may update this policy from time to time, so please review it frequently. We will notify you of material changes via a notice on our home page before they go into effect or by in-app notification. Your continued use of our products means you accept the changes. 

Once you accept this policy, we will not enforce future changes we deem in good faith to be material absent your express agreement to the changed terms. If you are asked to affirmatively accept material changes to this policy and you decline to do so, you may not be able to continue to use the product provided.

 

  1. Contact Us

 

If you have a complaint or question about this policy, if you would like to make a request concerning your personal data, withdraw your consent, you may at any time contact us at hello@zillionwhales.com. We will aim to respond to you within maximum 10 working days from receipt of request.

All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

 

Responsible person contacts:

Name, surname: Olga Butyagina

E-mail: olga@zillionwhales.com