AcoinGames Privacy Policy
The practices described in this privacy policy statement are current as of 10 October 2018.
Who we are:
We are AcoinGames, a mobile game developer and publisher based in Chengdu, China. Our mission is to creates and publishes creative and fun mobile games to global players. AcoinGames is the controller of your personal information and is responsible for your personal information. All references in this policy to "AcoinGames", "our", "us" or "we" refer to AcoinGames, or our group companies, as appropriate. All references in this policy to "apps" are to our apps that are available to download on mobile devices from time to time.
The purpose of this policy：
We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here.
In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.
We are always looking to improve the information we provide to our customers and contacts, so if you have any feedback on this privacy policy, please let us know using our contact details :
.
Who this policy applies to:
This policy applies to users of our apps and people who contact our customer support function.
The content of this policy
: This privacy policy describes the following important topics relating to your information：
- Collection of your personal information and how we use it:
- Our legal basis for using your personal information;
- How and why we share your personal information with others;
- How long we store your personal information;
- Your rights;
- Children;
- Where we may transfer your personal information;
- Risks and how we keep your personal information secure;
- Changes to this privacy policy; and
- Further questions and how to make a complaint.
Your rights to object:
You have various rights in respect of our use of your personal information, as set out in section 5. Two of the fundamental rights to be aware of are that:1). you may ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose. 2). you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest. (You can find out more information in section 5).
What you need to do and your confirmation to us:
Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, including downloading and using any of our apps, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.
The key information you should be aware of: 1. Collection of your personal information and how we use it
1.1 What personal information we collect about you
(a) Our apps collect the following information about you (and we use the information in the ways explained below):
(i) data about your location, device type and model, operating system and version and platform;
(ii) data about your device, including your mobile phone network and operator, generated device identifier information, the Identifier for Advertising (IDFA) of the device, and the IP address;
(iii) data generated when you play our games, such as the game version you are playing, your high score, game progress (for example level attained), log-in method and rankings;
(iv) if you participate in any chat activity on our apps, we will collect your handle and any data that you share within your messages posted to that forum;
(v) data relating to your game play history on our apps, including any purchases made;
(vi) the number of times you have accessed a game via the relevant app from a particular mobile device and for how long; and
(vii) if you choose to use the Facebook connection functionality and depending on your Facebook privacy settings, your basic Facebook profile information.
(b) If you contact our customer support function, we will collect your e-mail address, your first name, your surname, your game progress and certain data about your device, including your mobile phone network and operator, and generated device identifier information (as well as any other information you include in your correspondence with us), including any updates to any of that information.
1.2 How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(a) to provide our apps to you, and to allow you to access and use them so that you can play our games;
(b) to recognise you when you return to our apps, keep your game progress and to store information about your use of our apps (for example the level you have attained on a particular game);
(c) to evaluate your use of our apps and compile statistics to understand the type of people who use our apps and how they use them. Such details will be anonymised as far as reasonably possible and you will not be identifiable by name from the information collected;
(d) to display your achievements on leader boards within the relevant app (which will include your basic Facebook profile information if you choose the Facebook connection functionality for that app and which will be visible to some other users of that app);
(e) to keep our apps and games secure;
(f) in order to restrict access to harmful, infringing or illegal chat content;
(g) to process any refunds requested by you;
(h) to send you push notifications with app-related information for certain of our apps (which you can choose not to accept or turn off by visiting the settings section of your device and selecting the appropriate setting);
(i) to optimise user experience, for example to ensure we have sufficient technical capacity to support the anticipated volume of players or fixing problems with our games;
(j) to help us manage advertising and provide you with advertising and marketing via our apps that is relevant to you, both from us and from our third party partners, as further described in the 'Third party advertising' section below;
(k) to record your preferences in relation to advertising and marketing communications; and
(l) to receive and respond to customer support enquiries we receive from you.
1.3 Other uses of your personal information
(a) We also collect, use and store your personal information for the following additional reasons:
(i) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. Even if we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
(ii) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
(iii) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(iv) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
(b) We will not use your personal information in any way that is incompatible with the purposes set out in this section 1. Please contact us using the details in section 10 if you want further information on the analysis we will undertake to establish if a new use of your personal information is compatible with these purposes.
2. Legal basis for use of your personal information
2.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
(a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of service of our apps); or
(b) you have provided us with your consent to do so. This applies in relation to the advertising and marketing materials delivered via our apps that are tailored to you and your preferences. You can control and withdraw your consent at any time on our apps.
(c) where (a) or (b) does not apply, our use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
(i) run, grow and develop our business (as well as the businesses of our group companies) including funding our business by use of advertising revenues;
(ii) operate, maintain and improve our apps and our marketing optimisation efforts;
(iii) understand the way in which our apps are used; and
(iv) for internal group administrative purposes.
If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details
.
3. How and why we share your personal information with others
3.1 Third Party Services.
Our Services may contain third party tracking and data collection and analytics tools from our service providers, examples of which include AppsFlyer (
). Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze user and device related data and information on our behalf. The third parties may have access to and collect data and information about you, such as your device identifier, geo-location information, IP address, application usage, access and session times, applications present on the device or in use at a particular time on the device, and your viewing of and interactions with advertising, for the purpose of providing their services, including, for example, enabling, providing and delivering advertising as described in further detail below.
The privacy policies of our service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.
3.2 Advertising.
To the extent we display advertising in our Services, we may allow advertising networks of our affiliates and partner networks to collect information about your mobile device to enable them to serve targeted ads to you. Such mobile device data includes the following:
• Device make, model and operating system;
• Device properties related to screen size & orientation, audio volume and battery;
• Carrier;
• Operating system;
• Name and properties of mobile application through which a consumer interacts with the Services;
• Country, time zone and locale settings (country and preferred language);
• Network connection type and speed;
• IP Address;
• Internet browser user-agent used to access the Services; and
• Identifier for advertisers (IDFA).
The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.
You may visit
or
(for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of interest based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice.
You may also limit data collection by third parties by using your mobile device settings. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. Additionally, please note that if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choices.
3.3 How We May Disclose Your Information to Third Parties
AcoinGames does not share your personal information except as approved by you or as described herein. We may share information we collect or derive with third parties for the following purposes:
• With service providers that perform services on our behalf, including the ones referenced above under “Third Party Services”;
• With our affiliates;
• For analytics and research purposes;
• In response to subpoenas, court orders, or other legal processes;
• To protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim;
• As part of a business transfer such as a merger, acquisition, or at bankruptcy;
• We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties; and
• We may use analytics services provided by third parties, including Google Analytics. These service providers may use cookies to collect information about your online activities across this and other sites over time for non-advertising purposes. To learn more about how Google analytics collects and processes data and the choices Google may offer to control these activities, you may visit
http://www.google.com/intl/en/policies/privacy/partners/
.
4. How long we store your personal information
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
5. Your rights
5.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at feedback@acoingames.com at any time. You have the following rights:
(a)
Right of access.
You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area.
(b)
Right to update your information.
You have a right to request an update to any of your personal information which is out of date or incorrect.
(c)
Right to delete your information.
You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details
. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.
(d)
Right to restrict use of your information.
You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details
.We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.
(e)
Right to data portability.
You have a right to ask us to provide your personal information to a third party provider of services.This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
(f)
Right to object.
You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
5.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
5.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
6. Children
6.1 You must be aged 12 or over to purchase products or services from us. Our website and services are not directed at children younger than this and we do not knowingly collect any personal information from children younger than this.
6.2 If you are aged below the age of 12 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
6.3 Please contact us at feedback@acoingames.com if you are aware that we may have inadvertently collected personal information from a child below the age of 12.
7. Where we may transfer your personal information
7.1. Your personal information will be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group or suppliers. Further details on to whom your personal information may be disclosed are set out in section 3.
7.2 When we provide any personal information about you to any such non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately. These measures may include the following, as permitted in Articles 45 and 46 of the General Data Protection Regulation:
(a) in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see https://www.privacyshield.gov/welcome); or
(b) entering into European Commission approved standard contractual arrangements with them.
7.3 Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us via the e-mail
.
8. Risks and how we keep your personal information secure
8.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
8.2 For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We use industry-standard practices such as encryption, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address will be encrypted, which will make it extra hard for someone to discover and use them without our authorisation. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our apps. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.
8.3 Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our apps or customer services function and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
9. Changes to our privacy policy
We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be made available to you via the privacy policy, accessible in our app. Please check back frequently to see any updates or changes to our privacy policy.
10. Further questions and how to make a complaint
10.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact feedback@acoingames.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
10.2 In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.