PRIVACY AND DATA POLICY
ISSUED BY AtoZgames
Last Updated: 17 JAN 2022
1. INTRODUCTION
AND GENERAL TERMS
Your privacy is important to AtoZgames and we are committed to protecting the privacy of parents and kids. Please take a moment to familiarize yourself with our privacy practices.
Your privacy is important to AtoZgames and we are committed to protecting the privacy of parents and kids. Please take a moment to familiarize yourself with our privacy practices.
These terms apply to the use of games and other products
developed by AtoZgames (AtoZ/ ‘we’ / ‘us’). Our registered office is at
International City PAK.
This privacy and data policy (“Privacy Policy”) applies
and has effect in respect of all games, related online services (including
online network play connectivity and interactivity) and other software and
products made available by us (together the “Game(s)“), as well as any other
online features relating to the Games including our website (the “Website”).
Together the Game(s), and Website are referred to as the “Online Services”.
If you have any questions or comments about this Privacy
Policy, please contact us at atozgames123@gmail.com
We are committed to protecting and respecting your
privacy. The Privacy Policy explains the basis on which personal information we
collect from you will be processed by us or on our behalf. Where we decide the
purpose or means for which personal data you supply through these Online
Services is processed, we are the “data controller.” We will comply with all
applicable data protection laws, including the General Data Protection
Regulation 2016/679.
Please read this Privacy Policy carefully as it contains
important information about the following:
• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else;
and
• Your choices and rights regarding the personal
information you have provided to us.
This Privacy Policy forms a part of and should be read in
conjunction with our terms of use.
The Online Services may contain hyperlinks to services
owned and operated by third parties. These third party services may have their
own privacy policies and we recommend that you review them. They will govern
the use of personal information that you submit or which is collected by
cookies and other tracking technologies whilst using these services. We do not
accept any responsibility or liability for the privacy practices of such third
party services and your use of these is at your own risk.
We may make changes to this Privacy Policy in future,
which will be posted on this page. You should check this page from time to time
to ensure you are aware of any changes. Where appropriate we may notify you of
changes through the Games.
2.
INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which
may include your personal data.
a) Information provided by you when using the Games
(“Basic Information”)
We may collect the following information from you when
you play our Games:
• Your mobile device’s unique device ID (Device ID);
• Your user preferences; and
• Core information related to your game play, such as
your overall progression to a particular level or stage, your virtual currency
stores or the completion of certain activities during your game play (for
example, completing a tutorial, passing a level, making a purchase or viewing a
video ad).
b) Information used for the purposes of serving
advertisements
(“Advertising Data”)
Through our third party advertising network partners, we
may gather information about your devices when you install or play our Games,
depending on the permissions you’ve granted. This may include:
• The make, model and operating system of your device;
• Properties of your device, such as screen size and
orientation, audio volume and battery;
• The mobile network operator linked to your device;
• The Games played;
• The country, time zone and locale settings on your
device (i.e. country and preferred language);
• Network connection type and speed;
• IP Address;
• MAC address;
• Internet browser used to access the Games; and
• The advertiser ID, which is an identifier unique to you
if you use an Apple or Android device, but which doesn’t reveal your name.
c) Information collected for the purposes of providing
analytics
(“Analytics”)
We may collect technical information about your use of
the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
• Your Device ID;
• Your user ID (which is generated by us and allocated to
you when you first play our games);
• Your device operating system & version;
• Your device make and model;
• Game play attempts, progression and results;
• Session game time start, end and duration;
• purchase transaction types and spend you have made
using virtual items in the Games;
• The country of your Device;
• The time, date and install source of your first
download (e.g. from a clicked advertisement);
• Advertisements viewed and clicked; and
• Identification of crashes and defects.
d) Information about you collected from third parties
(“Third Party Log In Information”)
When you access the Games via a third party social media
provider such as Facebook, we may collect and store personal and non-personal
information which is available on that third party social media provider, such
as your Facebook name, your profile picture or its URL, your Facebook ID and
other public data of your friends, provided that you have expressly agreed to
the use of Facebook within the Games. We will also receive technical data in
order to ensure the Games connect to the correct Facebook account.
3.
WHY WE COLLECT INFORMATION ABOUT YOU
a) To provide our Games to you
We will use information about you (including Basic
Information, Third Party Log in Information, Analytics and User Content) for
delivering our Games to you under the terms of use agreed between us. The
processing of information in this way is necessary for us to record your
progress and current status within a Game, and to ensure the Games deliver the
features promised and function properly, so that you have the best experience
when playing any one of our Games.
b) To help us improve the Online Services and fix any
problems
We may process information about you (including Basic
Information, User Content and Analytics) so that we can analyze and improve our
Games and Online Services.
This processing is also necessary for us to pursue our
legitimate interests of (i) ensuring that our Online Services function properly
so that you and other users have the best experience when playing any of our
Game(s) and using the other Online Services; (ii) improving the quality of our
Online Services, and providing a better experience to our users; (iii)
identifying and correcting any bugs in the Games and Online Services and iv)
understanding the effectiveness of our marketing to attract new users and
re-engage our current users at an aggregated level.
d) To acquire new users and engage current users
We may process information (including some Advertising
Data and Analytics) to encourage engagement from our less active users and to
notify them with new virtual items or other promotions on offer.
We may also process this information to pursue our
legitimate interests of acquiring new users for our Games.
We use various forms of marketing to acquire new users.
The information we collect about you may be used to improve the relevancy of
our marketing, including the creation of ‘lookalike’ audiences. This allows us
to offer more relevant marketing to potential new service users without using
information that personally identifies you.
e) To improve the monetization of the Games via in-app
purchases
We may process information (including Basic Information,
User Content, Advertising Data and Analytics) to understand how users use our
Games, and to compile statistical reports regarding that activity, as well as
understanding how users progress, and their current status within a Game. This
processing is necessary for us to pursue our legitimate interests of improving
the Games and increasing the amount of revenue generated via in-app purchases.
This may include the implementation of dynamic pricing models, so that in-app
purchases are priced according to relevant factors, such as geography and game
play progression so that we can offer temporary promotional discounts.
f) For advertising purposes
We may process Advertising Data to show you
advertisements for third party services; including advertising that may reward
you with benefits during your use of the Games.
The information we collect about you may be used to
understand how advertisements placed in our Games have performed or how many
people have viewed certain advertisements. We aggregate this information so
that it does not personally identify you or permit you to be treated
individually.
We may also use this information to reward users with
benefits that can be used for further enjoyment of the Games from the viewing
of certain advertising placed in our Games.
We will not pass or process your information for the
purposes of marketing by third parties unless you give your consent should we
ask for it. After you have given your consent, you may withdraw it at any time.
We may use the information we collect about you to serve
you targeted advertisements in our Games. We do this to provide you with more
relevant advertising content. We work with the following third party
advertising networks :
• Chart boost –
https://answers.chartboost.com/en-us/articles/115001489623
• Ad colony – https://www.adcolony.com/privacy-policy/
• Face book –
https://www.facebook.com/privacy/explanation
• Unity – https://unity3d.com/legal/privacy-policy
• Google – https://policies.google.com/technologies/ads
If you would like to find out more about the way these
third parties collect and process your information please refer to their
respective privacy policies and/or terms and conditions by clicking on the
links provided above.
g) To prevent fraud and illegal activity
We process personal data for our legitimate interests of
ensuring that any use of the Online Services is lawful and non-fraudulent, does
not disrupt the operation of our services, does not harass our staff or other
individuals, to enforce our legal rights and to comply with our legal
obligations.
Where we reasonably believe that you are or may be in
breach of any applicable laws or our terms of use, we may use your personal
information to inform relevant third parties such as your law enforcement
agencies about the content.
We reserve the right to disclose your identity to any
third party who is claiming that any User Content posted by you constitutes a
violation of their intellectual property rights, or of their right to privacy.
You may not copy, download, or embed any User Content without the express
written permission of the content owner. You may not use any User Content for
any commercial purposes, or any public performances.
We work with Apple and Google to assist us with fraud
prevention and the detection of any illegal activity (e.g. to verify in-app
purchases made through iTunes and Google Play).
4. DATA SHARING
We will share your information with third parties only in
the ways that are described in this Privacy Policy
Group members, personnel, suppliers or subcontractors: We
keep your information confidential, but may disclose it to any member of our
group (which means our subsidiaries, our ultimate holding company and its
subsidiaries, as defined in section 1159 of the Companies Act 2006), our
personnel, suppliers or subcontractors insofar as it is reasonably necessary
for the purposes set out in this Privacy Policy. However, this is on the basis
that they do not make independent use of the information, and have agreed to
safeguard it.
Merger or acquisition: If we are involved in a merger,
acquisition, or sale of all or a portion of its assets, any third party to
which we sell or transfer our assets to will have the right to continue to use
the personal and other information that you provide us in the manner set out in
this Privacy Policy.
Required by law: In addition, we may disclose your
information to the extent that we are required to do so by law (which may
include to government bodies and law enforcement agencies); in connection with
any legal proceedings or prospective legal proceedings; and in order to
establish, exercise or defend our legal rights (including providing information
to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal
information to third parties in order to enforce or apply the terms of
agreements, to investigate potential breaches, or to protect the rights,
property or safety of ATOZ, our customers, or others.
Digital Content Stores: Where the Games are downloaded
through Google Play, iTunes and/or Amazon Appstore, we may disclose your
personal information to Google, Apple and/or Amazon respectively for the
purposes of facilitating any in-Game payments made through these platforms.
5.
AUTOMATED DECISION MAKING
We may use automated decision making methods which do not
involve human involvement to process your information only in the ways that are
described in this Privacy Policy
We may process your personal information via automated
decision making methods in order to identify users who are suspected of
cheating in the Games. Our automated decision making methods are designed to
detect cheating by looking out for (i) excessive currency stores against actual
completed game play; and (ii) excessive content against actual purchases made
and completed game play.
If users are determined to be or suspected of cheating
the following actions may be taken and which will be unknown to the user:
• An increase in the number of advertisements displayed
within the Games; and
• An increase in the frequency of suspected cheats
playing against other suspected cheats.
We may block users from the Games and/or the Online
Services who are determined to be cheating following an automated decision
process. In this scenario the user will be notified of the outcome and will
have the right to obtain human intervention to express his or her point of view
and to contest the decision to block access to the Games and/or the Online
Services.
6.
CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to be part of a lookalike campaign,
receive notifications from us or be served with targeted advertisements you can
opt-out by changing your advertising and notification settings on your device
directly.
You can withdraw your consent to targeted advertising by
changing your advertising settings on your device at any time.
7.
YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process
personal data relating to you, as set out in the table below. We aim to comply
without undue delay, and within one month at the latest.
To make a request, please let our Data Protection Officer
know by sending an email to atozgames123@gmail.com.
a) Ask for a copy of data we are processing about you and
have inaccuracies corrected
You have the right to request a copy of ATOZ the personal information we hold about
you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by
law to supply, correct or delete personal information held about you on our
files (and with any third parties to whom it has been disclosed to).
b) Object to us processing data about you
You can ask us to restrict, stop processing, or to delete
your personal data if:
• You consented to our processing the personal data, and
have withdrawn that consent;
• We no longer need to process that personal data for the
reason it was collected;
• we are processing that personal data because it is in
the public interest or it is in order to pursue a legitimate interest of or a
third party, you don’t agree with that processing, and there is no overriding
legitimate interest for us to continue processing it;
• The personal data was unlawfully processed;
• You need the personal data to be deleted in order to
comply with legal obligations;
• The personal data is processed in relation to the offer
of a service to a child.
c) Obtain a machine readable copy of your personal data,
which you can use with another service provider
• If we are processing data in order to perform our
obligations to you, or because you consented, or if that processing is carried
out by automated means, we will help you to move, copy or transfer your
personal data to other IT systems.
• If you request, we will supply you with the relevant
personal data in digital format. Where it is technically feasible, you can ask
us to send this information directly to another IT system provider if you
prefer.
d) Make a complaint to a Supervisory Authority
• If you are unhappy with the way we are processing your
personal data, please let us know by contacting us via the email.
• If you do not agree with the way we have processed your
data or responded to your concerns, an alternative is to submit a complaint to
a Data Protection Supervisory Authority.
8.
DATA RETENTION
We will hold your personal information on our systems for
as long as is necessary for the relevant service, or as otherwise described in
this Privacy Policy.
9.
CHILDREN
We do not use our Online Services to knowingly solicit
information from or market to children under the age of 13. Our terms of use
prohibit users aged under 13 years from accessing our Online Services. In the
event that we learn that we have collected personal information from a child
under 13 years of age we will delete that information as quickly as possible.
If you believe that we might have any information from or about a child under
13 years of age please contact us at atozgames123@gmail.com.
10.
SECURITY
We will take all reasonable technical and organizational
precautions to prevent the loss misuse or alteration of your personal
information. For example, our databases are password protected and limited to
essential employees only (such as ATOZ management or employees whose main role
requires system access).
11. FILE ACCESSING and STORING
From media store images we are accessing memory of device, we need access to
get images from whatsapp folder that's why we need media files access, We are
not taking user's any personal Information and also we are not saving user's
personal data on server.
Information Disclosure & Security
In the following circumstances, we may disclose your personal information according to your wish or regulations by law:
(1) Your prior permission.
(2) By the applicable law within or outside your country of residence, legal process, litigation requests.
(3) By requests from public and governmental authorities.
(4) To protect our legal rights and interests. We take reasonable steps to secure your information against unauthorized access or disclosure. We encrypt transmission of data on pages where you provide payment information. However, no security or encryption method can be guaranteed to protect information from hackers or human error.
CONTACT
INFORMATION
All questions, comments or enquiries should be directed
to ATOZ at atozgames123@gmail.com. We will Endeavour to respond to any query or
questions within three business days.
© 2022 ATOZ GAMES Limited. All trademarks are the
property of the relevant owners. All rights reserved.