App Privacy Policy

COME2PLAY PRIVACY POLICY

Last Updated: July 10, 2018

This privacy policy (“Privacy Policy”) governs how we, Come2Play Ltd. (“Come2Play” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”) when you make use of our games, products, services, and content (collectively, the “Services”), in the following use cases:

  • When you sign up and/or use the Services;
  • When you commence direct communications with us in connection with the Services, for example by sending us a support related email; and
  • Advertising purposes

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Table of contents:

  • What Information we Collect, Why we Collect it, and How it is Used;
  • How we Protect and Store your Personal Data;
  • How we share your Personal Data
  • Additional Information Regarding Transfers of Personal Data
  • Your Rights
  • US Privacy Provisions
  • Use by Children
  • How to Contact Us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below.  If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data We Collect Why is the data collected and for what purposes? Legal basis Third Parties with whom we Share your Data Period of Storage Consequences of not providing the data
User Facebook ID To identify you as the User (for fraud prevention purposes) Necessary to provide our Services to you. AWS
OVH
Hetzner servers (CDH)
for as long as you continue to use our Services. You will not be able to use our Services.
We use your User Facebook ID in order to send you advertising materials relating to our Services Consent for as long as you continue to use our Services We will not be able to send you materials relating to our Services which we believe you would be interested in
User Facebook Access Token Access to Facebook APIs (so you  will be able to share things on his Facebook account directly from the game) Necessary to provide our Services to you AWS
OVH
Hetzner servers (CDH)
for as long as you continue to use our Services. You will not be able to share your progress with your friends
User Link To Avatar On Facebook  To show you your profile picture from Facebook in the game Consent AWS
OVH
Hetzner servers (CDH)
for as long as you continue to use our Services We won’t be able to provide your with marketing materials
User Full Name To communicate with you and to show you your personal profile in the game Necessary to provide our Services to you AWS
OVH
Hetzner servers (CDH)
Zendesk
Pushwoosh
for as long as you continue to use our Services. We will not be able to communicate with you and share your game progression with you
User Link To Avatar On Facebook   Consent AWS
OVH
Hetzner servers (CDH)
for as long as you continue to use our Services. We won’t be able to provide your with marketing materials
User Email (as long as You provided it through Facebook) To communicate with you in connection with the Services, for example to respond to enquiries. Necessary to provide our Services to you Amazon
OVH
Hetzner servers (CDH)
Zendesk
Appsflyer
for as long as is reasonably necessary for us to adequately respond to your enquiry. We will not be able to respond to your enquiry(ies).
User IP Address To identify you as the User(if you choose to stay as a guest and not connect to the Services through Facebook) Necessary to provide our Services to you. It is also necessary for the purpose of our legitimate interest to avoid User fraud Amazon
OVH
Hetzner servers (CDH)
Appsflyer
Bidalgo
Zendesk
Pushwoosh
for as long as you continue to use our Services. You will not be able to use our Services.
User Device ID To identify you as the User (if you choose to stay as a guest and not connect to the Services through Facebook) Amazon
OVH
Hetzner servers (CDH)
Appsflyer
Zendesk
Pushwoosh
for as long as you continue to use our Services. You will not be able to use our Services.
Cookies When you use our Services, we will collect and receive information collected from cookies implemented by us and other third parties, in order to provide you with the best user experience, improve our Services and target you relevant with marketing campaigns on social media or by email.
For additional information about our cookie policy, please see here
Consent Facebook
Google Analytics
If you choose to opt out, as soon as reasonably practicable, and within a maximum of 30 days We will not be able to improve our Services, or provide you with content and offrs which may be of interest to you

 

 2. INFORMATION ABOUT YOU THAT WE GET FROM THIRD-PARTIES

  1. If you play or access our Services through connected third party applications, or connect our Services to third party applications (such as Facebook), we will receive certain information (including Personal Data, as described in Section 1) about you from the provider of such third party applications (such as Facebook). The scope of information we receive depends on your third party application privacy settings.
  2. If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s terms of service and privacy policy.
  3. If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

 

3. HOW WE PROTECT AND STORE YOUR INFORMATION

  1. Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  2. Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

 

4.HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described in Section 1, we may share your information as follows:

  • Where you have provided your consent to us using and sharing your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality);
  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.

 

5. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

  1.  Where we transfer your Personal Data outside of Come2Play, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or
  2.  Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

 

6. YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR:

  • You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.
  • You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
  • The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
  • The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
  • The right to withdraw your consent. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
  • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

 

You can exercise your rights by contacting us at info@come2play.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.  When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

 

7. US PRIVACY PROVISIONS

  1.  California Privacy Rights. California Civil Code Section 1798.83 (and other, similar state statutes) permits our customers who are California residents (or residents of states with similar statutes) to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to info@come2play.com.
  2. Our Do Not Track Notice. We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
  3. Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Data you have publicly posted.  If you wish to remove such content or Personal Data and you specify which content or Personal Data you wish to be removed, we will do so in accordance with applicable law.  Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

 

8. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under 16, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

 

9. CONTACT US

 If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@come2play.com.

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