Privacy Policy

Last updated: 29 February 2020

EFFECTIVE DATE: JANUARY 25, 2023

FEAVY GAMES OÜ Website

Privacy Policy

Content

  1. Who collects and process your Personal Data
  2. Which Personal Data do we collect and process
  3. Term of Personal Data processing and place of storage
  4. Third persons and your Personal Data
  5. Your rights under the GDPR
  6. Cookies and similar technology
  7. Age limits
  8. Contact us

1. Who collects and process your Personal Data:

1.1.

When you (1) play the games developed by us and/or by our partner developers(“Game(s)”) or (2) send us e-mails to www.feavygames.com we can collect information about you thatcan directly or indirectly identify you (“Personal Data”).

1.2.

Please note that we have partner developers who are also engaged in thedevelopment of the Games. Our partner developers may also collect Personal Data in the Games.For the avoidance of doubt, the processing of Personal Data in the Games by our partnerdevelopers is outside the scope of this Privacy Policy and we are not responsible for suchprocessing. For more information you may refer to our partner developers and their privacypolicies.

1.3.

Please note that we have partner publishers with which we publish our Games. Ourpartner publishers may also collect Personal Data. For the avoidance of doubt, the processing ofPersonal Data by the partner publishers with which we publish our Games is outside the scope ofthis Privacy Policy, and we are not responsible for such processing. For more information, youmay refer to the partner publishers and their privacy policies.

1.4.

This Privacy Policy provides (1) theGame players (app users); (2) e-mail senders (users)which contact to the e-mail feavygames@gmail.com. Unless expressly provided otherwise, all of thefollowing terms apply to all of the above categories of data subjects.

1.5.

The controller of your Personal Data who determines purposes and means of theprocessing is FEAVY GAMES OÜ, registered in the Register of Legal Entities of the Republic ofEstonia on December 30, 2015, under Registration code 12970318, legal address: Republic of Estonia,Punane tn 68, 13619, Tallinn linn, Harju maakond (“we”, “us”, “our”, etc.).

1.6.

We collect Personal Data in the following ways: when you play our Games, contact us insocial networks (we may also collect information about you available on such social network) or contactus via e-mail feavygames@gmail.com.

1.7.

We may periodically update this Privacy Policy. Your continued use of the Games orcommunication after the effective date of the updated Privacy Policy will be subject to the new PrivacyPolicy. If we make any major changes to our Privacy Policy and will need your explicit consent forfurther processing of your Personal Data, we will request your consent or your renewed consent (in case itwas obtained previously).

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT PLAY OUR GAMES.

2. Warranties and Disclaimers:

2.1.

We respect your privacy and aim to limit the Personal Data that we collect from youto the amount which is strictly necessary to fulfil the purposes of processing. Categories ofPersonal Data that we process are specified below.

2.2.

Your Personal Data is used as follows:

In game users

Purpose of the processing

In order to check and improve the quality of Games content we need to collect data about:

  • Frames per second (FPS) of the Games acrossdifferent devices;
  • Progress of passing the Games by users (arethere any stages that are too difficult);
  • How long users play Games;
  • How many users keep playing the Games for along time;
  • Games testing;
  • Are ads displayed and are ads working properlywith Games content.

Type of Personal Data

Game data:

  • Game name;
  • Game configuration version;
  • session ID;
  • event ID;
  • Game event type (e.g., “install”,“level_completed”, “show_ad”);
  • event context (arbitrary key/value pairsfor in Game event data, soft/hardcurrency, placement). This field can befilled with specific and custom datadepending on the event, Game and user(for example, some are shown only to thepaid users). The data list is determinedpartially by our partner developers andmay be changed. The type of data whichis collected is Game play data;
  • FPS Game information;
  • event time;
  • install time.

Device data:

  • device name;
  • OS name;
  • Unity device ID=device ID;
  • advertiser ID (GAID/IDFA), deviceIDFA;
  • attribution network device ID - externaldevice ID (Adjust ID).

Legal ground for theprocessing

The legitimate interestbased on the balance ofinterests:

  • Your interest is in receiving Games with high-quality content;
  • Our interest is in attracting more Game players and keeping them.

Purpose of the processing

In order to identify problems in the Games and fix them we need to collect data about:

  • Game freeze/suspension;
  • Inability to load the Game;
  • Problems while passing the Game;
  • Checking the display and operation of ads in the application;
  • Errors, warnings;

Type of Personal Data

Game data:

  • Game name;
  • Game configuration version;
  • session ID;
  • event ID;
  • Game event type (e.g., “install”,“level_completed”, “show_ad”);
  • event context (arbitrary key/value pairs for in Game event data, soft/hard currency, placement). This field can be filled with specific and custom data depending on the event, Game and user (for example, some are shown only to the paid users). The data list is determined partially by our partner developers and may be changed. The type of data which is collected is errors and/or exceptions;
  • FPS Game information;
  • event time;
  • install time.

Device data:

  • device name;
  • OS name;
  • Unity device ID=device ID;
  • advertiser ID (GAID/IDFA), deviceIDFA;
  • attribution network device ID - externaldevice ID (Adjust ID).

Legal ground for theprocessing

The legitimate interest based on the balance of interests:

  • Your interest is in playing Games free from any errors, warnings and other problems;
  • Our interest is in attracting more Game players and keeping them.

Purpose of the processing

In order to analyze financial information we need to collect data about:

  • How many ads are viewed by users;
  • What income does the Game bring (viewing ads, purchases);
  • User acquisition costs;

Type of Personal Data

Advertisement data:

  • ads type (e.g., interstitial / banner / rewarded);
  • advertisement placement name;
  • impressions count;
  • revenue figures;
  • specific and custom data depending on the event, Game and user (for example, some fields are shown only to the paid users). The data list is determined partially by our partner developers and may be changed. The type of data which is collected is acquisition, monetization and advertisement data as well as purchase data

Attribution data:

  • source (ad network identifier);
  • campaign name;
  • creatives name;
  • source_app_id (adgroup ID - Adjust Attribution manager data);
  • tracker token (token ID - Adjust Attribution manager data).

Device data:

  • device name;
  • OS name;
  • Unity device ID=device ID;
  • advertiser ID (GAID/IDFA), device IDFA;
  • attribution network device ID - externaldevice ID (Adjust ID).

Legal ground for theprocessing

The legitimate interest based on the balance of interests:

  • Your interest is in receiving relevant and valuable ads;
  • Our interest is in attracting more Game players and keeping them; analyzing the effectiveness of the ads.

Purpose of the processing

We group users by number / countries / by activity in order to determine the audience for the acquisition of users and monetization

Type of Personal Data

Attribution data:

  • source (ad network identifier);
  • campaign name;
  • creatives name;
  • source_app_id (adgroup ID - Adjust Attribution manager data);
  • tracker token (token ID - Adjust Attribution manager data).

GeoIP:

  • IP;
  • country;
  • ASN name.

Game data:

  • Game name;
  • Game configuration version;
  • session ID;
  • event ID;
  • Game event type (e.g., “install”, “level_completed”, “show_ad”);
  • event context (arbitrary key/value pairs for in Game event data, soft/hard currency, placement). This field can be filled with specific and custom data depending on the event, Game and user (for example, some are shown only to the paid users). The data list is determined partially by our partner developers and may be changed. The type of data which is collected is Game play data;
  • FPS Game information;
  • event time;
  • install time.

Device data:

  • device name;
  • OS name;
  • Unity device ID=device ID;
  • advertiser ID (GAID/IDFA), device IDFA;
  • attribution network device ID - external device ID (Adjust ID).

Legal ground for theprocessing

The legitimate interest based on the balance of interests:

  • Your interest is in discovering new Games that you may be interested in; receiving relevant and valuable ads;
  • Our interest is in attracting more Game players and keeping them; analyzing the effectiveness of the ads.

Visitors (users) of our website www.feavygames.com or social media users

Purpose of the processing

You may contact us via social media or email feavygames@gmail.com.

Type of Personal Data

  • Email;
  • Personal information from the social media via which you contacted us;
  • Other data that you provide in your query

Legal ground for the processing

The legitimate interestbased on the balance of interests:

  • Your interest is in receiving response to your query;
  • Our interest is in ensuring good customer service, and providing you with the prompt personalised reply to your enquiry. and/or finding potential suitable employee.

Other

Purpose of the processing

We may need to provide the potential investor and/or his legal counsels with information necessary to conduct due diligence, including with Personal Data of (1) Game players (app users); (2) e-mail senders (users) which contact to the e-mail feavygames@gmail.com

Type of Personal Data

Information requested by the potential investor and/or his legal counsels

Legal ground for the processing

The legitimate interestbased on the balance of interests:

  • Your interest is in interaction with us who will have new resources;
  • Our interest is in attracting new investors and receiving new resources.

2.3.

We do not use automated decision-making and profiling

3. Term of Personal Data processing and place of storage

3.1.

We retain your Personal Data for as long as it is necessary to fulfil the purposesspecified in the section “Which Personal Data do we collect and process”.

3.2.

The time limits are:

Once these time periods have expired, we will delete your data as soon as possible.

3.3.

We securely store your data at servers provided by Google Cloud which arephysically located in Finland (EU). We also take security precautions such as:

4. Third persons and your Personal Data

4.1.

Third persons that we share your personal data with:

4.1.1.

We may share your Personal Data collected and processed by us (i) in the Games but only for the purposes specified in section “Which Personal Data do we collect and process” with the companies (third persons) specified in clause 4.1.3 below.

4.1.2.

Please note that some of these companies (or some of their offices/group members) may be located outside the European Union (international data transfers) including in the countries which do not ensure an adequate level of protection of your Personal Data. Where this is the case, we meet the strict conditions of Personal Data transfers from the member states of European Union to other countries by using the Standard Contractual Clauses (SCC) adopted by the European Commission to ensure that Personal Data are properly protected or relying on other derogations compliant with GDPR as specified in clause 4.1.3 below. In case you want to check the relevant SCC, the links to them are provided in clause 4.1.3. If the link is not provided and you want to check the SCC, please, contact us by using one of the contact means specified in section “Contact us”.

4.1.3.

The list of third persons with whom we may share your Personal Data:

Product / business metrics services

Its privacy policy and SCC (if applicable)

https://policies.google.com/privacy?hl=en

Transfer to the USA and Singapore based on Firebase Data Processing and Security Terms

Purposes of transfer

Checking the quality of Games content.

Its privacy policy and SCC (if applicable)

https://gameanalytics.com/privacy/

Transfer to the USA and Singapore based on Firebase Data Processing and Security Terms

Purposes of transfer

Checking the quality of Games content.

Attribution services

Its privacy policy and SCC (if applicable)

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

Transfer to India, Thailand, China, Ukraine, the Russian Federation, the USA, Brazil, Hong Kong and Australia based on Data Processing Addendum

Purposes of transfer

Marketing analysis

Its privacy policy and SCC (if applicable)

https://www.adjust.com/terms/privacy-policy/

Transfer to the USA, Mexico, Brazil, Singapore, China, India, Turkey and the Russian Federation based on Data Processing Agreement

Purposes of transfer

Checking the quality of Games content

Identification of problems in the Games Financial analysis

Crash and error support services

Its privacy policy and SCC (if applicable)

https://policies.google.com/privacy?hl=en

Transfer to the USA and Singapore based on Firebase Data Processing and Security Terms

Purposes of transfer

Identification of problems in the Games

Its privacy policy and SCC (if applicable)

https://gameanalytics.com/privacy/

Purposes of transfer

Identification of problems in the Games

Its privacy policy and SCC (if applicable)

https://unity.com/legal/privacy-policy

Transfer to the USA based on the Data Processing Addendum

Purposes of transfer

Checking the quality of Games content

Identification of problems in the Games

Marketing analysis

User acquisition, monetization and mediation services

https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

Transfer to the USA based on the Data Processing Terms

Purposes of transfer

Financial analysis

https://unity.com/legal/privacy-policy

Transfer to the USA based on the Data Processing Terms

Purposes of transfer

Financial analysis

https://policies.google.com/privacy?hl=en

Transfer to the USA and Singapore based on Google Ads Controller-Controller Data Protection Terms and Google Ads Data Processing Terms

Purposes of transfer

Financial analysis

https://policies.google.com/privacy?hl=en

Transfer to the USA and Singapore based on Google Ads Controller-Controller Data Protection Terms and Google Ads Data Processing Terms

Purposes of transfer

Financial analysis

https://policies.google.com/privacy?hl=en

Transfer to the USA and Singapore based on Google Ads Controller-Controller Data Protection Terms and Google Ads Data Processing Terms

Purposes of transfer

Financial analysis

https://www.applovin.com/privacy/

Transfer to the USA based on Data Processing Agreement and Data Processing Addendum (controller-controller)

Purposes of transfer

Financial analysis

https://www.mintegral.com/en/privacy/

Transfer to the USA, the Russian Federation, India, Singapore, China, Hong Kong, Seychelles based on the consent

Purposes of transfer

Financial analysis

https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/#step-1

TTransfer to the USA, China and India based on the Data Protection Addendum

Purposes of transfer

Financial analysis

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

Transfer to China, India, the UAE, Vietnam, Turkey, Indonesia, South Africa, the USA, Philippines, the Russian Federation, Singapore, Australia based on the Data Processing Agreement

Purposes of transfer

Financial analysis

https://ads.tiktok.com/i18n/official/policy/privacy

Transfer to the USA, the Russian Federation, the UAE, Indonesia, India based on the Jurisdiction Specific Terms and Controller to Controller Data Terms

Purposes of transfer

Financial analysis

https://vungle.com/privacy/

Transfer to the USA, China and Singapore based on Data Privacy Addendum

Purposes of transfer

Financial analysis

https://www.digitalturbine.com/fyber-services-privacy-statement/

Purposes of transfer

Financial analysis

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

Transfer to the USA, India, Singapore, to the UAE, China, Australia, Malaysia, Indonesia, Vietnam based on Advertiser Data Protection Rider, Publisher Data Protection Rider, Affiliate Promotion Property: Demand - Data Protection Rider and Affiliate Promotion Property: Supply - Data Protection Rider

Purposes of transfer

Financial analysis

https://www.pangleglobal.com/privacy

Transfer to China, the USA, the UAE, India, Singapore, Indonesia and others based on the Partner Service Agreement (Appendix 1: EEA/ Swiss/ UK Specific Terms)

Purposes of transfer

Financial analysis

https://www.smaato.com/privacy/

Purposes of transfer

Financial analysis

Our partner developers

We may also transfer Personal Data related to the Games to our partner developers by granting access to Personal Data via our internal website, but in a personalized and limited way: a user from the specific team /studio/company will only see data for Games owned by this team/studio/company and not for Games owned by our other partner developers.

4.2.

Third persons that may process your personal data independently from us

4.2.1.

Other third persons may process your personal data with regard to your use of the Games as independent controllers of your personal data when you make in-app purchases payments or save your game progress via such third persons.

4.2.2.

When you make payments related to the Game(s), you submit your payment details to the relevant app store (Google Play Store, Apple App Store) that processes your payments. We only receive a limited amount of information from such third person, such as product ID, price and currency, purchase time, transaction ID, etc. We do not receive any personal information about you or your bank details. Please, refer to the privacy policy of the relevant public app store to check how it processes your payment data:

Google Play Store https://policies.google.com/privacy

Apple App Store https://www.apple.com/legal/privacy/data/en/app-store/

4.2.3.

When you play the Game(s) with the Cloud Save feature while signed in to Game Center, Apple Inc. collects your Game data allowing you to save your progress in the Game. This Game data is processed by Apple according to its own policy: https://www.apple.com/legal/privacy/data/en/game-center/. We will only have access to your Apple Game Center ID, but not your name and other data that will allow us to easily associate your Game Center ID with other information that may identify you, like your IP address. You can stop sending your Game data to Game Center by signing out of Game Center in Apple Settings.

5. Your rights under the GDPR

5.1.

You have following rights under the GDPR:

5.2.

You may exercise these rights by means of an email sent to our email address or written notice sent to the address of our registered office. We will address your request as early as possible and no longer that within one month. Please note that this period may be extended by two further months where necessary, taking into account the complexity and number of the requests. In this case, we will inform you of the extension within one month of receipt of your request and will explain you the reasons for the delay.

5.3.

Note that if you ask us to delete your Personal Data, we may retain your Personal Data as necessary to comply with our legal obligations or resolve disputes.

6. Cookies and similar technology

6.1.

We do not use any cookies on the website www.feavygames.com, it means that we do not collect or track any user’s personal data while using our website (www.feavygames.com)

6.2.

7. Age limits

7.1.

We do not knowingly collect or solicit Personal Data about or direct or target personalized advertisements to anyone under the age of 16, or knowingly allow such persons to use our Games of websites. If you are under the age of 16, please do not send any Personal Data to us. If we learn that we have collected Personal Data about a child under age 16, we will delete that Personal Data as quickly as possible. If you believe that we might have any Personal Data from or about a child under the age of 16, please contact us.

8. Contact us

8.1.

Would you have any questions regarding the processing of your Personal Data by us, do not hesitate to contact us under the email address: feavygames@gmail.com.