ViroPlay Privacy Policy
Last Updated: December 6, 2024
Last Updated: December 6, 2024
This Privacy Policy explains who we are, how we handle your personal information (i.e., collect, record,
organize, structure, store, adapt or alter, retrieve, consult, use, disclose, transfer, disseminate, or
otherwise make available, align, or combine, restrict, delete, or destroy), and how you can exercise your
privacy rights. We are ViroPlay , a developer and publisher of games and mobile gaming applications
available through app stores, including the Apple App Store and Google Play Store. This Privacy Policy
applies to personal information we collect through our games, mobile applications, and other products
("games") collectively referred to as “services.” By using our services, you agree to be bound by this
Privacy Policy and consent to our handling of your information as described herein.
We collect most of the information about you directly from your interactions with our games or from third-party ads within our games or advertisements we place in other publishers' games. Generally, the information we collect about you relates to the type of device you're using, helping us identify your device, how you play our games, and may include information you voluntarily submit to contact us. We may also collect information from app store platforms, partners, and other third parties, such as your interests and in-app purchases (although we never receive your payment or credit card information).
The information we collect through the services generally falls into the following categories:
(a) Information You Provide Voluntarily
Certain parts of our services may require you to voluntarily provide personal information. For example, we may ask you for certain details to process an inquiry, such as:
· Your name, email address, or other contact information necessary to address your inquiry;
· Any information you submit to our support team via email.
We will try to explain why we need your personal information at the time we request it.
(b) Information We Collect Automatically
When you use our services, we may automatically collect certain information about you and/or your device, in accordance with applicable data protection laws, such as:
· Information about how you use our services (e.g., in-game progress, levels completed, game session duration, settings preferences, in-game ads viewed, or game preferences).
· Your IP address and device identifiers (e.g., your advertising ID or device ID; for more information, see our section on advertising IDs and device IDs).
· The type of device and operating system you are using.
· Broad geographic location (e.g., country or city-level location based on your IP address).
· Precise geographic location based on your IP address.
Advertising IDs refer to the Apple Identifier for Advertisers (IDFA) on Apple and the Google Advertising ID (GAID) on Google devices. These are unique identifiers used by advertisers for personalized ads on mobile devices. They are present across all mobile apps, allowing for cross-app tracking. On Apple devices, you can opt out by selecting the "Limit Ad Tracking" option in your privacy settings. On Google Android, you can opt out by selecting the "Opt out of personalized ads" option. Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device.
Device Identifiers/Information refer to the device type, device model, device manufacturer, device operating system, and its language or other technical data (e.g., screen size or processor), or a combination of such data obtained by developers from the device, used to check compatibility with specific applications.
Some of this information may be collected via cookies, as described in the "Cookies" section.
(c) Information From Third-Party Sources
We may receive information about you from third-party social networks (e.g., Google Play Games, Apple Game Center, Facebook) and other partners or third parties.
Third-Party Social Networks: You may choose to connect to our services via your social media account. The information we receive from your social media will depend on your privacy settings, but it generally includes your basic public profile information, such as your username, gender, and friends who are playing the same game. (See "Third-Party Social Networks" below for more details.)
Third-Party Service Providers: We may receive your personal information from third-party sources. For example, we may obtain your personal information when you install our game and prior to installation, if you clicked on an advertisement for the same game.
Advertising Partners: From time to time, we may also receive personal information from other third-party sources. For example, if you click on an advertisement that directs you to our services (such as an ad for one of our games shown in another publisher’s game), we will receive information about the ad network and the campaign from which the install originated (see "Advertising" below for more details).
(d) No Special Categories of Information
We do not request or intend to collect any “special categories of information,” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, genetic data, biometric data used to uniquely identify a person, data concerning health, or data concerning a person’s sex life or sexual orientation. Please exercise caution when sharing information about yourself (or others) on our forums.
(a) General Use
We use the information we collect about you/your device to provide our services and games to you, and to operate our business. We also use it to improve our services and games, enhance security, and for analysis and research purposes to ensure we provide the best experience possible. Additionally, we use your information to promote our services and games in our games and other publishers' apps and to show you third-party ads. We also use your information for tracking and preventing fraud, for advertising purposes, and to comply with our legal obligations.
We use your information for the following purposes:
· Delivering and Improving Our Services: We use your information to develop, deliver, and improve our games and other products, services, and content, customize our products and services, provide game updates, perform technical troubleshooting, understand and analyze usage trends, and manage our games.
· Displaying Ads: We use your information to show ads for our games in other publishers' apps, as well as in our games. Please refer to the "Advertisements" section of this Privacy Policy for more details.
· Cross-Promotion: We use your information for cross-promotion, meaning promoting one of our games while you are playing another.
· Tracking and Fraud Prevention for Advertising: We use your information to track the performance of our ad campaigns and to identify and prevent fraudulent advertising activities.
· Analysis and Research: We use your information to understand and analyze game usage, collect demographic data about our user base, and understand where our games are being downloaded. We may also create reports and analysis for research or business intelligence purposes, such as tracking potential issues or trends with our games and services, or testing new game features and content.
· Security: We use your information to enhance the security of our games, products, and services.
· Customer Support: We use your information to provide you with customer support and respond to your inquiries.
· Legal Obligations: We use your information where required by law, such as using your country or region to comply with tax reporting requirements.
(b) In-App Purchases
Our games enable in-app purchases. We do not process payments for in-app purchases, nor do we have access to your credit card information.
Payments for in-app purchase transactions are made through your App Store account, Google Play account, or Amazon.com account. Any post-purchase processes are controlled by Apple, Google, and Amazon.com stores, and are subject to their respective terms. Please review the privacy policies and terms of service for Apple, Google, and Amazon.com stores.
We cannot provide all the services necessary for the successful operation of our games by ourselves. Therefore, we must share the collected information with third parties to develop and provide our services, display advertisements, conduct analysis and research, and measure the effectiveness of our advertising campaigns with our partners. We also reserve the right to disclose your information (including personal identification information) in the following circumstances: when required by law, in an anonymized manner, and in aggregate form that cannot be used to identify you.
We may share such information for the following purposes:
· Our Analytics Providers: We use third-party analytics, such as TapJoy, Unity, and Firebase, to provide our services and for analysis and research purposes. The data we share with these providers is encoded. The providers can assign a random ID, and they cannot match it back to you. We can aggregate data for benchmarking purposes.
· Our Cloud Service Providers: We store the information we collect from you with our third-party cloud service providers, such as iCloud and Google Cloud Platform.
· Our Tracking and Fraud Prevention Vendors: For some of our games, we use tracking and anti-fraud vendors, such as AppsFlyer and Tenjin, to measure performance and optimize our advertising campaigns, display ads, analyze to improve our services, and prevent fraud. These providers may use APIs and SDKs in our games to collect and analyze user and device-related data, including impressions, clicks, installs, or other performance metrics of advertising campaigns and in-app events post-installation.
· Third-Party Advertising Partners: We have contracts with certain third-party advertising networks to help us serve ads to you, enabling us to continue offering games for free or at a low cost.
· Third-Party Tracking Vendors for Advertising Partners: We allow our advertising partners to track impressions, clicks, installs, or other performance metrics of their advertising campaigns to measure their effectiveness. They may use their own third-party tracking vendors.
· Other Third-Party Service Providers: For our games, we use Unity software to develop such games. For information on Unity's data processing, please refer to Unity's privacy policy at Unity Privacy Policy. For certain games, we collaborate with third-party development studios. These third-party studios do not have access to your personal information; they only have access to aggregated data that cannot be traced back to you.
We may enter into contracts with other partners or change existing partners in the future to provide any services related to the games. These changes will be updated from time to time or promptly when there are significant changes in data processing practices.
We reserve the right to disclose your information (including personal identification information) in response to legal requests, legal processes, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose your information if we determine that it is necessary or appropriate for national security, law enforcement, or other public interest matters. Additionally, we may disclose your information if we determine that disclosure is necessary to enforce our terms and conditions or to protect our operations, users, or user experience. Furthermore, in the event of a restructuring, merger, or sale, we may transfer any of our information (including personal identification information) collected to the relevant third parties.
For any questions regarding the collection of information by third parties, please refer to privacy policy.
(a) General Information
We use advertisements to fund our services and provide our games for free. We offer our games for free or at a low cost, and to achieve this, we need to share the information we collect from you with our third-party advertising partners. To protect your privacy, we only temporarily store personal information. The information we collect helps us improve our website and games while keeping our games free for a broad range of players.
The third-party services we may integrate include:
· Google SDK: Privacy Policy
· Firebase SDK: Privacy Policy
· Unity SDK: Privacy Policy
· Applovin SDK: Privacy Policy
· Appsflyer SDK: Privacy Policy
· Facebook SDK: Privacy Policy
· Fyber SDK: Privacy Policy
· Bigo SDK: Privacy Policy
· InMobi SDK: Privacy Policy
· Mintegral SDK: Privacy Policy
· Pangle SDK: Privacy Policy
· TradPlus SDK: Privacy Policy
· Vungle SDK: Privacy Policy
· Yandex SDK: Privacy Policy
· Maticoo SDK: Privacy Policy
· Sanyi SDK: Privacy Policy
· Bugly SDK: Privacy Policy
If you are a user in the European Economic Area (EEA), please note:
When you use our games, we show ads to you based on our legitimate interests. The legal basis for displaying advertisements to EEA users is compliant with the legitimate interests outlined in Article 6(1)(f) of the General Data Protection Regulation (GDPR), and we work closely with our data protection officer. Additionally, we ensure that data processing agreements with external advertising technology providers comply with Article 28 of the GDPR. We also ensure that our external service providers are committed to a high level of data protection through strict protection agreements.
Before sharing any information with our advertising partners for personalized advertising, we always seek your consent when you accept via the relevant button while loading the game. We allow our advertising partners to share your personal information for personalized advertising purposes only if you consent in the relevant pop-up window. Our advertising partners use different technologies to achieve personalized advertising, so please review their data processing practices before you accept personalized advertising when loading the game. The legal basis for showing personalized ads to users based in the EEA is based on Article 6(1)(a) of the GDPR. Additionally, we ensure compliance with Article 28 of the GDPR with our external advertising technology providers. We are committed to a high level of data protection for our external service providers. The goal is to improve our games and provide players with more relevant advertisements. You can choose to withdraw your consent to share your personal information for personalized advertising at any time. You can do this by going to the game settings and clicking the Terms & Privacy button in the section for withdrawing personalized advertising consent within the privacy policy. You can manage your preferences regarding the types of ads you wish to receive. When you decide to withdraw consent, or if you do not provide consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they will not be based on your preferences, interests, behaviors, demographics, etc. Our advertising partners may continue to display ads based on the content of the applications you are using.
In-Game Advertising (i.e., when you view ads within our games)
To enable us to display in-game ads, we may share your Advertising ID and IP address with advertisers to help them find suitable ads to display to you in our games and third-party platforms. You can manage this in your device settings. We cannot control which specific ads are displayed in our games (this is controlled by the advertising platforms), but we do limit certain categories of ads.
Advertising platforms use Advertising IDs for various purposes (see the privacy statements of our advertising partners listed), including:
· Limiting the number of times you see the same ad;
· Ensuring they interact with real users on devices, rather than “automated” bots;
· Providing ads that are relevant to you (based on your Advertising ID and interactions with other brands), and recording ads based on your Advertising ID and general geographical location. Other brands purchase advertising space in our games through advertising platforms or ad exchanges. Advertising networks or ad exchanges act as intermediaries between other gaming companies and us. They track clicks on ads and potential installs of applications from other developers. The number of views, clicks, and installs of ads is measured using the advertising ID.
· Tracking similar games that you use for marketing purposes. Advertisers typically use IP addresses to understand your approximate geographical region (country, state, and sometimes at the city level).
(c) Viewing Our Ads on Third-Party Services
We also advertise our games through advertising networks in other applications to reach audiences interested in them (identified using Advertising IDs).
Advertising platforms use Advertising IDs for various purposes (see the privacy statements of our advertising partners listed), including:
· Measuring ad effectiveness (viewing the aggregate impressions, clicks, and installs generated through ads in other publishers' games);
· Informing players who have not played the game for some time about new content in the game. This is done through the advertising platform’s advertising ID. Then, the ad network displays ads about new content to these users;
· Not displaying ads in games where players are already playing. We can manage this through the ad network's advertising ID. The ad network will then prevent these players from seeing ads;
· Promoting games to a group of potential players.
(d) Who Can Show You Personalized Ads?
Please refer to the list of advertising providers below that allow personalized advertising and review their data processing practices, including the technologies they use for personalized purposes.
(e) How to Opt Out of Personalized Advertising?
In addition to specific tools available for users in the EEA, you can use your device settings.
iOS
Open the "Settings" app on iOS, then select the "Privacy" menu item, and choose the "Advertising" sub-item. If you enable the "Limit Ad Tracking" option, we can only take limited measures, such as identifying unique users or combating fraud. In the same menu, you can always delete your IDFA (by selecting “Reset Ad-ID”), creating a new unmerged ID that will not use previously collected data.
Android
Open the "Settings" app and select the "Google" menu item. Depending on your device, this option may not be visible in the main menu, but you can find it using the search function at the top of the personal settings menu. From there, select the "Ads" sub-item and activate the option "Opt out of personalized ads" to prevent the creation of profiles and the display of personalized ads. You can also use the same menu (by selecting "Reset Advertising ID"), creating a new ID that will not merge with previously collected data.
(a) Connecting to Third-Party Social Networks
Some of our games use third-party services, such as Google Play Games Services, Apple Game Center, and Facebook (referred to as "Third-Party Social Networks"). These games allow you to log in to your third-party social network accounts using the "Login" feature in our application. You can also share content created within the application on these third-party social networks. Please note that third-party social networks are governed by their own privacy policies, terms, and end-user agreements, for which we are not responsible and cannot control the sharing practices or policies of the parties operating those sites. For any other questions, please contact us at viroplay@sina.com.
(b) Information We May Receive When You Connect to Third-Party Social Networks
The information you allow us to access varies by application and is subject to the privacy settings you have established on these third-party social networks. You can control and learn more about these settings from the respective third-party social networks. When you use the "Login" feature, we may access and store some or all of the following information, as permitted by you, the third-party social network, and your preferences: (i) basic information from your public profile, such as your nickname and profile picture; (ii) login ID and/or player identifier string; (iii) your friend list; (iv) notifications displayed during the "Login" process. We may share your name and game data (such as steps, game progress, and scores) with applicable applications, friends who also use the "Login" feature, or with contacts related to the "Connect to" feature within the applicable third-party social media network accounts.
The application may further request your permission to disclose information on your behalf to these third-party social networks (such as status updates). Please remember that we will only do this with your explicit consent and will store your ID and full name for user identification purposes. Other information will only be stored within the application on your device to allow the application to communicate directly with the third-party social networks.
(c) How You Share Your Information with Third-Party Social Networks
If you engage in game-related activities (such as leaderboards and multiplayer games) using third-party social networks, you share your information (for example, scores, rankings, and achievements) with other players and the third-party social networks.
Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent from websites and stored on your computer's hard drive. We use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use certain options of our services.
Based on relevant policy requirements and legal regulations, please be aware that we do not knowingly collect or seek personal data about any child under the age of 13, nor do we intentionally allow such children to use our services. If you are a child, please do not send us any personal data about yourself; if we become aware that we have collected personal data about a child, we will delete that data as soon as possible. If a guardian or parent believes that we may have data from or about a child under 13, please contact us promptly at viroplay@sina.com, so that we can address the situation.
For more details regarding our children’s privacy policy, you can click here to view it. If you would like to review or delete your or your child's information, or request information about our applications or our vendors and service providers, please contact us at viroplay@sina.com.
If you are a user based in the EEA, you have certain rights regarding your personal information and how we process it. Some of these rights may be subject to certain exceptions or limitations. Your rights include:
Right to be Informed: According to GDPR, you have the right to know the categories, sources, and purposes of your personal data that we collect, as well as whether your personal data is shared, transferred, or sold. (For example, you can refer to this privacy policy or contact us directly for processing.)
Right to Withdraw Consent: Under GDPR Article 7(3), you have the right to withdraw your consent (for instance, you can withdraw your consent for personalized advertising by accessing your game settings and following the instructions in the Consent Withdrawal section of the privacy policy, applicable only to EEA users).
Right of Access: Under GDPR Article 15, you have the right to access your data (for example, you can view the data we store about you by accessing your game’s Terms and Privacy settings and following the instructions in the Request a Summary of Personal Data section of the privacy policy, applicable only to EEA users).
Right to Rectification: Under GDPR Article 16, you have the right to correct your data (for example, if your email address has changed, we should replace your old email address).
Right to Erasure: Under GDPR Article 17, you have the right to have your data deleted (for example, you can contact us if you wish for us to delete certain data we store about you by accessing your game settings and following the instructions in the Delete Personal Data section of the privacy policy, applicable only to EEA users).
Right to Restrict Processing: Under GDPR Article 18, you have the right to restrict the processing of your personal information (for example, if you want to restrict processing, you can contact us).
Right to Data Portability: Under GDPR Article 20, you have the right to data portability (for example, you can contact us if you want to upload your data to other services, and we will receive your data).
Right to Object: Under GDPR Article 21, you have the right to object to how your data is processed (for example, you can contact us if you disagree with any user analytics described in this privacy policy).
Right to Opt-Out of Sharing and Selling Your Data: Under GDPR, you have the right to choose not to have your personal data shared or sold. However, such “sharing” and “selling” require your explicit consent, and we do not engage in any selling practices. (For example, if you choose not to have your personal data “shared” or “sold,” you can contact us directly for processing.)
Right to Lodge Complaints: Under GDPR Article 77(1)(f), you have the right to lodge a complaint with a supervisory authority (for example, you can contact your local data protection authority directly).
Your information privacy and security are very important to us. We always pay special attention to ensuring that we process your information in accordance with the EEA data protection laws applicable to EEA users. We have designated a Data Protection Officer to help us ensure compliance with EEA data protection laws. We will store your information as needed to provide our services. We may store information for longer periods, but only in a way that does not allow for the identification of you. Our business operates globally, and we collaborate with our partners (please refer to our current partner list) for the purposes outlined in the "How We Share Your Information" section above, which may include transferring your personal information outside of the European Economic Area (EEA). Please check our privacy policy regularly for changes.
Contract Necessity: This includes processing the information required to provide you with the services you have requested and agreed upon, such as delivering and improving our services, providing customer support, offering special features in our games (like in-app chat, multiplayer features, leaderboards, and third-party social network features), and delivering in-app purchase content you make.
Legitimate Interests: This includes processing your information to pursue our legitimate interests in ensuring you have the best experience while using our applications, keeping your information secure, and providing services at little or no cost. We pay special attention to your data protection rights to ensure they are not overridden by our legitimate interests. We rely on our legitimate interests for data analysis, tracking, fraud prevention, push notifications, cross-promotion, and contextual advertising purposes.
Consent: In cases where we request your consent to use your data for specific purposes, we will make clear how you can withdraw your consent at the time of collection. We will seek your consent before sharing any information with our advertising partners for personalized ads or conducting any surveys.
Legal Obligations: This includes processing information necessary to comply with legal obligations, such as maintaining records for tax purposes.
We have implemented appropriate technical and organizational measures to protect the confidentiality, security, and integrity of information contrary to this privacy policy and to prevent unauthorized access and use. While we make commercially reasonable efforts to ensure the security of the information we maintain, please note that no security measures are perfect or invulnerable.
We will store your information as needed to provide our services. We may store information for longer periods, but only in a way that does not allow for identification of you. We will delete information as soon as we no longer need it for the purposes outlined in this privacy policy and in any event no later than when you have stopped using all our games. We will retain your information as long as we have a legal obligation to do so. If you request the deletion of your data, we will delete it as outlined in the "Your Rights" section above.
(a) California Privacy Protection
Under the California Consumer Privacy Act (CCPA), if you are a resident of California, you have the data protection rights provided by the CCPA, applicable where the law applies. For example:
· Right to Know: You have the right to request disclosure of the personal information we have collected about you and how we have used it over the past 12 months (e.g., you have the right to know if your personal information has been shared or sold).
· Right to Correction: If you find your personal data to be inaccurate or outdated, you have the right to request correction of that data according to CCPA.
· Right to Deletion: You have the right to request deletion of your personal information. Upon confirming your request, we will delete your personal information from our records, except where exceptions apply under the CCPA.
· Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format to provide to other entities, and you can contact us for assistance.
· Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the sale or sharing of your personal information, but in practice, we do not sell your personal information to any third party. We will not share your personal data with other third parties without your explicit consent.
· Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of the rights provided by the CCPA.
All requests for these rights can be directed to us for processing. We will handle your requests after verifying your identity and confirming your specific requests.
(b) Virginia Privacy Protection
Under the Virginia Consumer Data Protection Act (VCDPA), users in Virginia have the following rights: You have the right to request information about the processing of your personal data (right of access). When providing this information, we will explain data processing and provide an overview of stored data related to you so that you understand whether your personal information may be shared, sold, or transferred, among other things. If the data we store is inaccurate or outdated, you have the right to correct it (right of correction). You may request the deletion of your data (right to deletion or right to be forgotten). If deletion is not possible due to VCDPA provisions, the processing will be limited for that purpose only. You may restrict the processing of your data if you believe the data we hold is inaccurate (right to restrict processing). You have the right to receive a copy of the personal data you provided (right to data portability). If we have collected and processed your personal data with your consent, you may withdraw your consent at any time. Withdrawal of your consent does not affect the legality of any processing that occurred before you withdrew it, nor will it affect the processing of your personal data based on legal grounds other than consent. To exercise the rights described here, you can contact us at any time.
(c) Brazil Privacy Protection
Under Brazil's General Data Protection Law (LGPD), users in Brazil have the following rights:
· Confirm whether we are processing your personal information and access that personal information.
· Correct inaccuracies in your personal information.
· Obtain a copy of your personal information that you have provided to us.
· Request that we refrain from processing your personal information for: (i) personalized advertising, (ii) selling your personal information, or (iii) profiling that significantly affects you. As stipulated by LGPD, you have the right to exercise the above rights without discrimination. If you fail to provide sufficient information for us to effectively respond when exercising the above rights, we may refuse your request. If you have any questions, please feel free to contact us.
If you have any questions or concerns regarding this privacy policy, please contact us to address privacy issues and exercise your rights through our privacy email:
Data Protection Officer (DPO): ViroPlay., Ltd.
Contact Email: viroplay@sina.com
1. Information We Collect From You
We collect most of the information about you directly from your interactions with our games or from third-party ads within our games or advertisements we place in other publishers' games. Generally, the information we collect about you relates to the type of device you're using, helping us identify your device, how you play our games, and may include information you voluntarily submit to contact us. We may also collect information from app store platforms, partners, and other third parties, such as your interests and in-app purchases (although we never receive your payment or credit card information).
The information we collect through the services generally falls into the following categories:
(a) Information You Provide Voluntarily
Certain parts of our services may require you to voluntarily provide personal information. For example, we may ask you for certain details to process an inquiry, such as:
· Your name, email address, or other contact information necessary to address your inquiry;
· Any information you submit to our support team via email.
We will try to explain why we need your personal information at the time we request it.
(b) Information We Collect Automatically
When you use our services, we may automatically collect certain information about you and/or your device, in accordance with applicable data protection laws, such as:
· Information about how you use our services (e.g., in-game progress, levels completed, game session duration, settings preferences, in-game ads viewed, or game preferences).
· Your IP address and device identifiers (e.g., your advertising ID or device ID; for more information, see our section on advertising IDs and device IDs).
· The type of device and operating system you are using.
· Broad geographic location (e.g., country or city-level location based on your IP address).
· Precise geographic location based on your IP address.
Advertising IDs refer to the Apple Identifier for Advertisers (IDFA) on Apple and the Google Advertising ID (GAID) on Google devices. These are unique identifiers used by advertisers for personalized ads on mobile devices. They are present across all mobile apps, allowing for cross-app tracking. On Apple devices, you can opt out by selecting the "Limit Ad Tracking" option in your privacy settings. On Google Android, you can opt out by selecting the "Opt out of personalized ads" option. Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device.
Device Identifiers/Information refer to the device type, device model, device manufacturer, device operating system, and its language or other technical data (e.g., screen size or processor), or a combination of such data obtained by developers from the device, used to check compatibility with specific applications.
Some of this information may be collected via cookies, as described in the "Cookies" section.
(c) Information From Third-Party Sources
We may receive information about you from third-party social networks (e.g., Google Play Games, Apple Game Center, Facebook) and other partners or third parties.
Third-Party Social Networks: You may choose to connect to our services via your social media account. The information we receive from your social media will depend on your privacy settings, but it generally includes your basic public profile information, such as your username, gender, and friends who are playing the same game. (See "Third-Party Social Networks" below for more details.)
Third-Party Service Providers: We may receive your personal information from third-party sources. For example, we may obtain your personal information when you install our game and prior to installation, if you clicked on an advertisement for the same game.
Advertising Partners: From time to time, we may also receive personal information from other third-party sources. For example, if you click on an advertisement that directs you to our services (such as an ad for one of our games shown in another publisher’s game), we will receive information about the ad network and the campaign from which the install originated (see "Advertising" below for more details).
(d) No Special Categories of Information
We do not request or intend to collect any “special categories of information,” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, genetic data, biometric data used to uniquely identify a person, data concerning health, or data concerning a person’s sex life or sexual orientation. Please exercise caution when sharing information about yourself (or others) on our forums.
2. How We Use Your Information
(a) General Use
We use the information we collect about you/your device to provide our services and games to you, and to operate our business. We also use it to improve our services and games, enhance security, and for analysis and research purposes to ensure we provide the best experience possible. Additionally, we use your information to promote our services and games in our games and other publishers' apps and to show you third-party ads. We also use your information for tracking and preventing fraud, for advertising purposes, and to comply with our legal obligations.
We use your information for the following purposes:
· Delivering and Improving Our Services: We use your information to develop, deliver, and improve our games and other products, services, and content, customize our products and services, provide game updates, perform technical troubleshooting, understand and analyze usage trends, and manage our games.
· Displaying Ads: We use your information to show ads for our games in other publishers' apps, as well as in our games. Please refer to the "Advertisements" section of this Privacy Policy for more details.
· Cross-Promotion: We use your information for cross-promotion, meaning promoting one of our games while you are playing another.
· Tracking and Fraud Prevention for Advertising: We use your information to track the performance of our ad campaigns and to identify and prevent fraudulent advertising activities.
· Analysis and Research: We use your information to understand and analyze game usage, collect demographic data about our user base, and understand where our games are being downloaded. We may also create reports and analysis for research or business intelligence purposes, such as tracking potential issues or trends with our games and services, or testing new game features and content.
· Security: We use your information to enhance the security of our games, products, and services.
· Customer Support: We use your information to provide you with customer support and respond to your inquiries.
· Legal Obligations: We use your information where required by law, such as using your country or region to comply with tax reporting requirements.
(b) In-App Purchases
Our games enable in-app purchases. We do not process payments for in-app purchases, nor do we have access to your credit card information.
Payments for in-app purchase transactions are made through your App Store account, Google Play account, or Amazon.com account. Any post-purchase processes are controlled by Apple, Google, and Amazon.com stores, and are subject to their respective terms. Please review the privacy policies and terms of service for Apple, Google, and Amazon.com stores.
3. How We Share Your Information
We cannot provide all the services necessary for the successful operation of our games by ourselves. Therefore, we must share the collected information with third parties to develop and provide our services, display advertisements, conduct analysis and research, and measure the effectiveness of our advertising campaigns with our partners. We also reserve the right to disclose your information (including personal identification information) in the following circumstances: when required by law, in an anonymized manner, and in aggregate form that cannot be used to identify you.
We may share such information for the following purposes:
· Our Analytics Providers: We use third-party analytics, such as TapJoy, Unity, and Firebase, to provide our services and for analysis and research purposes. The data we share with these providers is encoded. The providers can assign a random ID, and they cannot match it back to you. We can aggregate data for benchmarking purposes.
· Our Cloud Service Providers: We store the information we collect from you with our third-party cloud service providers, such as iCloud and Google Cloud Platform.
· Our Tracking and Fraud Prevention Vendors: For some of our games, we use tracking and anti-fraud vendors, such as AppsFlyer and Tenjin, to measure performance and optimize our advertising campaigns, display ads, analyze to improve our services, and prevent fraud. These providers may use APIs and SDKs in our games to collect and analyze user and device-related data, including impressions, clicks, installs, or other performance metrics of advertising campaigns and in-app events post-installation.
· Third-Party Advertising Partners: We have contracts with certain third-party advertising networks to help us serve ads to you, enabling us to continue offering games for free or at a low cost.
· Third-Party Tracking Vendors for Advertising Partners: We allow our advertising partners to track impressions, clicks, installs, or other performance metrics of their advertising campaigns to measure their effectiveness. They may use their own third-party tracking vendors.
· Other Third-Party Service Providers: For our games, we use Unity software to develop such games. For information on Unity's data processing, please refer to Unity's privacy policy at Unity Privacy Policy. For certain games, we collaborate with third-party development studios. These third-party studios do not have access to your personal information; they only have access to aggregated data that cannot be traced back to you.
We may enter into contracts with other partners or change existing partners in the future to provide any services related to the games. These changes will be updated from time to time or promptly when there are significant changes in data processing practices.
We reserve the right to disclose your information (including personal identification information) in response to legal requests, legal processes, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose your information if we determine that it is necessary or appropriate for national security, law enforcement, or other public interest matters. Additionally, we may disclose your information if we determine that disclosure is necessary to enforce our terms and conditions or to protect our operations, users, or user experience. Furthermore, in the event of a restructuring, merger, or sale, we may transfer any of our information (including personal identification information) collected to the relevant third parties.
For any questions regarding the collection of information by third parties, please refer to privacy policy.
4. Advertising
(a) General Information
We use advertisements to fund our services and provide our games for free. We offer our games for free or at a low cost, and to achieve this, we need to share the information we collect from you with our third-party advertising partners. To protect your privacy, we only temporarily store personal information. The information we collect helps us improve our website and games while keeping our games free for a broad range of players.
The third-party services we may integrate include:
· Google SDK: Privacy Policy
· Firebase SDK: Privacy Policy
· Unity SDK: Privacy Policy
· Applovin SDK: Privacy Policy
· Appsflyer SDK: Privacy Policy
· Facebook SDK: Privacy Policy
· Fyber SDK: Privacy Policy
· Bigo SDK: Privacy Policy
· InMobi SDK: Privacy Policy
· Mintegral SDK: Privacy Policy
· Pangle SDK: Privacy Policy
· TradPlus SDK: Privacy Policy
· Vungle SDK: Privacy Policy
· Yandex SDK: Privacy Policy
· Maticoo SDK: Privacy Policy
· Sanyi SDK: Privacy Policy
· Bugly SDK: Privacy Policy
If you are a user in the European Economic Area (EEA), please note:
When you use our games, we show ads to you based on our legitimate interests. The legal basis for displaying advertisements to EEA users is compliant with the legitimate interests outlined in Article 6(1)(f) of the General Data Protection Regulation (GDPR), and we work closely with our data protection officer. Additionally, we ensure that data processing agreements with external advertising technology providers comply with Article 28 of the GDPR. We also ensure that our external service providers are committed to a high level of data protection through strict protection agreements.
Before sharing any information with our advertising partners for personalized advertising, we always seek your consent when you accept via the relevant button while loading the game. We allow our advertising partners to share your personal information for personalized advertising purposes only if you consent in the relevant pop-up window. Our advertising partners use different technologies to achieve personalized advertising, so please review their data processing practices before you accept personalized advertising when loading the game. The legal basis for showing personalized ads to users based in the EEA is based on Article 6(1)(a) of the GDPR. Additionally, we ensure compliance with Article 28 of the GDPR with our external advertising technology providers. We are committed to a high level of data protection for our external service providers. The goal is to improve our games and provide players with more relevant advertisements. You can choose to withdraw your consent to share your personal information for personalized advertising at any time. You can do this by going to the game settings and clicking the Terms & Privacy button in the section for withdrawing personalized advertising consent within the privacy policy. You can manage your preferences regarding the types of ads you wish to receive. When you decide to withdraw consent, or if you do not provide consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they will not be based on your preferences, interests, behaviors, demographics, etc. Our advertising partners may continue to display ads based on the content of the applications you are using.
In-Game Advertising (i.e., when you view ads within our games)
To enable us to display in-game ads, we may share your Advertising ID and IP address with advertisers to help them find suitable ads to display to you in our games and third-party platforms. You can manage this in your device settings. We cannot control which specific ads are displayed in our games (this is controlled by the advertising platforms), but we do limit certain categories of ads.
Advertising platforms use Advertising IDs for various purposes (see the privacy statements of our advertising partners listed), including:
· Limiting the number of times you see the same ad;
· Ensuring they interact with real users on devices, rather than “automated” bots;
· Providing ads that are relevant to you (based on your Advertising ID and interactions with other brands), and recording ads based on your Advertising ID and general geographical location. Other brands purchase advertising space in our games through advertising platforms or ad exchanges. Advertising networks or ad exchanges act as intermediaries between other gaming companies and us. They track clicks on ads and potential installs of applications from other developers. The number of views, clicks, and installs of ads is measured using the advertising ID.
· Tracking similar games that you use for marketing purposes. Advertisers typically use IP addresses to understand your approximate geographical region (country, state, and sometimes at the city level).
(c) Viewing Our Ads on Third-Party Services
We also advertise our games through advertising networks in other applications to reach audiences interested in them (identified using Advertising IDs).
Advertising platforms use Advertising IDs for various purposes (see the privacy statements of our advertising partners listed), including:
· Measuring ad effectiveness (viewing the aggregate impressions, clicks, and installs generated through ads in other publishers' games);
· Informing players who have not played the game for some time about new content in the game. This is done through the advertising platform’s advertising ID. Then, the ad network displays ads about new content to these users;
· Not displaying ads in games where players are already playing. We can manage this through the ad network's advertising ID. The ad network will then prevent these players from seeing ads;
· Promoting games to a group of potential players.
(d) Who Can Show You Personalized Ads?
Please refer to the list of advertising providers below that allow personalized advertising and review their data processing practices, including the technologies they use for personalized purposes.
(e) How to Opt Out of Personalized Advertising?
In addition to specific tools available for users in the EEA, you can use your device settings.
iOS
Open the "Settings" app on iOS, then select the "Privacy" menu item, and choose the "Advertising" sub-item. If you enable the "Limit Ad Tracking" option, we can only take limited measures, such as identifying unique users or combating fraud. In the same menu, you can always delete your IDFA (by selecting “Reset Ad-ID”), creating a new unmerged ID that will not use previously collected data.
Android
Open the "Settings" app and select the "Google" menu item. Depending on your device, this option may not be visible in the main menu, but you can find it using the search function at the top of the personal settings menu. From there, select the "Ads" sub-item and activate the option "Opt out of personalized ads" to prevent the creation of profiles and the display of personalized ads. You can also use the same menu (by selecting "Reset Advertising ID"), creating a new ID that will not merge with previously collected data.
5. Third-Party Social Networks
(a) Connecting to Third-Party Social Networks
Some of our games use third-party services, such as Google Play Games Services, Apple Game Center, and Facebook (referred to as "Third-Party Social Networks"). These games allow you to log in to your third-party social network accounts using the "Login" feature in our application. You can also share content created within the application on these third-party social networks. Please note that third-party social networks are governed by their own privacy policies, terms, and end-user agreements, for which we are not responsible and cannot control the sharing practices or policies of the parties operating those sites. For any other questions, please contact us at viroplay@sina.com.
(b) Information We May Receive When You Connect to Third-Party Social Networks
The information you allow us to access varies by application and is subject to the privacy settings you have established on these third-party social networks. You can control and learn more about these settings from the respective third-party social networks. When you use the "Login" feature, we may access and store some or all of the following information, as permitted by you, the third-party social network, and your preferences: (i) basic information from your public profile, such as your nickname and profile picture; (ii) login ID and/or player identifier string; (iii) your friend list; (iv) notifications displayed during the "Login" process. We may share your name and game data (such as steps, game progress, and scores) with applicable applications, friends who also use the "Login" feature, or with contacts related to the "Connect to" feature within the applicable third-party social media network accounts.
The application may further request your permission to disclose information on your behalf to these third-party social networks (such as status updates). Please remember that we will only do this with your explicit consent and will store your ID and full name for user identification purposes. Other information will only be stored within the application on your device to allow the application to communicate directly with the third-party social networks.
(c) How You Share Your Information with Third-Party Social Networks
If you engage in game-related activities (such as leaderboards and multiplayer games) using third-party social networks, you share your information (for example, scores, rankings, and achievements) with other players and the third-party social networks.
6. Cookies
Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent from websites and stored on your computer's hard drive. We use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use certain options of our services.
7. Children's Privacy
Based on relevant policy requirements and legal regulations, please be aware that we do not knowingly collect or seek personal data about any child under the age of 13, nor do we intentionally allow such children to use our services. If you are a child, please do not send us any personal data about yourself; if we become aware that we have collected personal data about a child, we will delete that data as soon as possible. If a guardian or parent believes that we may have data from or about a child under 13, please contact us promptly at viroplay@sina.com, so that we can address the situation.
For more details regarding our children’s privacy policy, you can click here to view it. If you would like to review or delete your or your child's information, or request information about our applications or our vendors and service providers, please contact us at viroplay@sina.com.
8. Your Rights
If you are a user based in the EEA, you have certain rights regarding your personal information and how we process it. Some of these rights may be subject to certain exceptions or limitations. Your rights include:
Right to be Informed: According to GDPR, you have the right to know the categories, sources, and purposes of your personal data that we collect, as well as whether your personal data is shared, transferred, or sold. (For example, you can refer to this privacy policy or contact us directly for processing.)
Right to Withdraw Consent: Under GDPR Article 7(3), you have the right to withdraw your consent (for instance, you can withdraw your consent for personalized advertising by accessing your game settings and following the instructions in the Consent Withdrawal section of the privacy policy, applicable only to EEA users).
Right of Access: Under GDPR Article 15, you have the right to access your data (for example, you can view the data we store about you by accessing your game’s Terms and Privacy settings and following the instructions in the Request a Summary of Personal Data section of the privacy policy, applicable only to EEA users).
Right to Rectification: Under GDPR Article 16, you have the right to correct your data (for example, if your email address has changed, we should replace your old email address).
Right to Erasure: Under GDPR Article 17, you have the right to have your data deleted (for example, you can contact us if you wish for us to delete certain data we store about you by accessing your game settings and following the instructions in the Delete Personal Data section of the privacy policy, applicable only to EEA users).
Right to Restrict Processing: Under GDPR Article 18, you have the right to restrict the processing of your personal information (for example, if you want to restrict processing, you can contact us).
Right to Data Portability: Under GDPR Article 20, you have the right to data portability (for example, you can contact us if you want to upload your data to other services, and we will receive your data).
Right to Object: Under GDPR Article 21, you have the right to object to how your data is processed (for example, you can contact us if you disagree with any user analytics described in this privacy policy).
Right to Opt-Out of Sharing and Selling Your Data: Under GDPR, you have the right to choose not to have your personal data shared or sold. However, such “sharing” and “selling” require your explicit consent, and we do not engage in any selling practices. (For example, if you choose not to have your personal data “shared” or “sold,” you can contact us directly for processing.)
Right to Lodge Complaints: Under GDPR Article 77(1)(f), you have the right to lodge a complaint with a supervisory authority (for example, you can contact your local data protection authority directly).
9. General Terms
Your information privacy and security are very important to us. We always pay special attention to ensuring that we process your information in accordance with the EEA data protection laws applicable to EEA users. We have designated a Data Protection Officer to help us ensure compliance with EEA data protection laws. We will store your information as needed to provide our services. We may store information for longer periods, but only in a way that does not allow for the identification of you. Our business operates globally, and we collaborate with our partners (please refer to our current partner list) for the purposes outlined in the "How We Share Your Information" section above, which may include transferring your personal information outside of the European Economic Area (EEA). Please check our privacy policy regularly for changes.
10. Legal Basis
Contract Necessity: This includes processing the information required to provide you with the services you have requested and agreed upon, such as delivering and improving our services, providing customer support, offering special features in our games (like in-app chat, multiplayer features, leaderboards, and third-party social network features), and delivering in-app purchase content you make.
Legitimate Interests: This includes processing your information to pursue our legitimate interests in ensuring you have the best experience while using our applications, keeping your information secure, and providing services at little or no cost. We pay special attention to your data protection rights to ensure they are not overridden by our legitimate interests. We rely on our legitimate interests for data analysis, tracking, fraud prevention, push notifications, cross-promotion, and contextual advertising purposes.
Consent: In cases where we request your consent to use your data for specific purposes, we will make clear how you can withdraw your consent at the time of collection. We will seek your consent before sharing any information with our advertising partners for personalized ads or conducting any surveys.
Legal Obligations: This includes processing information necessary to comply with legal obligations, such as maintaining records for tax purposes.
11. Security
We have implemented appropriate technical and organizational measures to protect the confidentiality, security, and integrity of information contrary to this privacy policy and to prevent unauthorized access and use. While we make commercially reasonable efforts to ensure the security of the information we maintain, please note that no security measures are perfect or invulnerable.
12. Retention
We will store your information as needed to provide our services. We may store information for longer periods, but only in a way that does not allow for identification of you. We will delete information as soon as we no longer need it for the purposes outlined in this privacy policy and in any event no later than when you have stopped using all our games. We will retain your information as long as we have a legal obligation to do so. If you request the deletion of your data, we will delete it as outlined in the "Your Rights" section above.
13. Supplementary Privacy Protection Information for Specific Regions
(a) California Privacy Protection
Under the California Consumer Privacy Act (CCPA), if you are a resident of California, you have the data protection rights provided by the CCPA, applicable where the law applies. For example:
· Right to Know: You have the right to request disclosure of the personal information we have collected about you and how we have used it over the past 12 months (e.g., you have the right to know if your personal information has been shared or sold).
· Right to Correction: If you find your personal data to be inaccurate or outdated, you have the right to request correction of that data according to CCPA.
· Right to Deletion: You have the right to request deletion of your personal information. Upon confirming your request, we will delete your personal information from our records, except where exceptions apply under the CCPA.
· Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format to provide to other entities, and you can contact us for assistance.
· Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the sale or sharing of your personal information, but in practice, we do not sell your personal information to any third party. We will not share your personal data with other third parties without your explicit consent.
· Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of the rights provided by the CCPA.
All requests for these rights can be directed to us for processing. We will handle your requests after verifying your identity and confirming your specific requests.
(b) Virginia Privacy Protection
Under the Virginia Consumer Data Protection Act (VCDPA), users in Virginia have the following rights: You have the right to request information about the processing of your personal data (right of access). When providing this information, we will explain data processing and provide an overview of stored data related to you so that you understand whether your personal information may be shared, sold, or transferred, among other things. If the data we store is inaccurate or outdated, you have the right to correct it (right of correction). You may request the deletion of your data (right to deletion or right to be forgotten). If deletion is not possible due to VCDPA provisions, the processing will be limited for that purpose only. You may restrict the processing of your data if you believe the data we hold is inaccurate (right to restrict processing). You have the right to receive a copy of the personal data you provided (right to data portability). If we have collected and processed your personal data with your consent, you may withdraw your consent at any time. Withdrawal of your consent does not affect the legality of any processing that occurred before you withdrew it, nor will it affect the processing of your personal data based on legal grounds other than consent. To exercise the rights described here, you can contact us at any time.
(c) Brazil Privacy Protection
Under Brazil's General Data Protection Law (LGPD), users in Brazil have the following rights:
· Confirm whether we are processing your personal information and access that personal information.
· Correct inaccuracies in your personal information.
· Obtain a copy of your personal information that you have provided to us.
· Request that we refrain from processing your personal information for: (i) personalized advertising, (ii) selling your personal information, or (iii) profiling that significantly affects you. As stipulated by LGPD, you have the right to exercise the above rights without discrimination. If you fail to provide sufficient information for us to effectively respond when exercising the above rights, we may refuse your request. If you have any questions, please feel free to contact us.
14. Contact Us
If you have any questions or concerns regarding this privacy policy, please contact us to address privacy issues and exercise your rights through our privacy email:
Data Protection Officer (DPO): ViroPlay., Ltd.
Contact Email: viroplay@sina.com