PRIVACY AND DATA POLICY

ISSUED BY: Free for MediaZClouds

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by Free for Media Zclouds (SG / ‘we’ / ‘us’). Our registered office is at Istanbul, Turkey.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)”), as well as any other online features relating to the Games including our website (the “Website”). Together the Game(s) and Website are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at [email protected].

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Games.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data.

a) Information provided by you when using the Games (“Basic Information”)

• Your mobile device’s unique device ID (Device ID);
• Your user preferences; and
• Core information related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores or the completion of certain activities during your gameplay (for example, completing a tutorial, passing a level, making a purchase or viewing a video ad).

b) Information used for the purposes of serving advertisements (“Advertising Data”)

Through our third-party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:

• The make, model and operating system of your device;
• Properties of your device, such as screen size and orientation, audio volume and battery;
• The mobile network operator linked to your device;
• The Games played;
• The country, time zone and locale settings on your device (i.e. country and preferred language);
• Network connection type and speed;
• IP Address;
• MAC address;
• Internet browser used to access the Games; and
• The advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.

c) Information collected for the purposes of providing analytics (“Analytics”)

• Your Device ID;
• Your user ID (which is generated by us and allocated to you when you first play our games);
• Your device operating system and version;
• Your device make and model;
• Gameplay attempts, progression and results;
• Session game time start, end and duration;
• Purchase transaction types and spend you have made using virtual items in the Games;
• The country of your Device;
• The time, date and install source of your first download (e.g. from a clicked advertisement);
• Advertisements viewed and clicked; and
• Identification of crashes and defects.

d) Information about you collected from third parties (“Third Party Log In Information”)

When you access the Games via a third-party social media provider such as Facebook, we may collect and store personal and non-personal information which is available on that third-party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook within the Games.

3. WHY WE COLLECT INFORMATION ABOUT YOU

We use your data to provide, improve, and protect our Games and Online Services. This includes processing information for gameplay, analytics, advertising, and fraud prevention.

4. DATA SHARING

We will share your information with third parties only as described in this Privacy Policy.

5. AUTOMATED DECISION MAKING

We may use automated decision-making methods to detect cheating or fraudulent behavior in our Games. Users identified as cheating may be restricted or blocked.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

You can withdraw your consent to targeted advertising or notifications by changing your device settings at any time.

7. YOUR RIGHTS

You have rights to access, correct, delete, or restrict processing of your data. To make a request, contact [email protected].

8. DATA RETENTION

We retain your personal information only as long as necessary for the purposes described in this policy.

9. CHILDREN

We do not knowingly collect data from children under 13. If you believe we have, contact us immediately at [email protected].

10. SECURITY

We take reasonable precautions to protect your personal data. However, no system is completely secure.

CONTACT INFORMATION

All questions, comments or enquiries should be directed to SG at [email protected]. We will endeavour to respond within three business days.