Last updated: January 17th 2021
The term, “Personal Data”, as used in this Policy means information relating to an identified or identifiable natural person.
The term, “processing”, as used in this Policy means any action taken in respect of the data.
We may change this Policy from time to time in order to keep you apprised of our data collection and use practices. We encourage you to regularly visit and review this Policy to stay informed of such practices.
Table of Contents
Personal Data we collect and how we use it
- When you access and use our App or interact with our Services (automatically collected data)
- When you visit and use our Site (automatically collected data)
- When you log in to our Services through your Facebook account
- When you contact us (including for support)
- When you make a payment or enter payment information on the Services
- When we receive data from our business contacts
How (and with whom) we Share Personal Data
- Cloud and Hosting Services
- Law Enforcement or Other Government Entities
- With your Consent
- Mergers and Acquisitions
- Additional Information on our Service Providers
How Long we Retain Personal Data
Your GDPR Rights
Transfers of Personal Data to other Countries outside the EU or EEA
Your California Privacy Rights
- Disclosure of Direct Marketing Practices (“Shine the Light”)
- Removal of Public Information of Minors
California Do Not Track Notice
Personal Data of Children
Third-Party Websites, Services & Data Collection
Our Contact Information
Personal Data We Collect and How We Use It.
We collect and receive Personal Data from outside our company and affiliates, such as from users of our products and services as described in the table below. Certain Personal Data is collected automatically, while other Personal Data is provided by you voluntarily, for example, when you contact us. The description in the table may be supplemented by additional information in other parts of this Policy. For example, you may find for more information on third-parties to whom your information may be transferred in Section 2 below.
2. How (and with whom) we Share Personal Data
In addition to any methods or third parties with whom we may share your Personal Data described above, we share Personal Data in the following manner:
2.1. Cloud and Hosting Services. We use cloud storage providers to host the Services and store all information we collect. We currently engage Amazon Web Services EMEA, SARL, and Google, LLC (or one of its affiliates), for such services and in addition to the third parties listed in Section 1 above, copies of all data we collect are stored on their servers.
2.2. Law Enforcement or Other Government Entities. Where required by law or government or court order, we will disclose Personal Data relating to you to the extent we believe we are required by law.
2.3. With your Consent. In the event that you have requested or have consented to the transfer of Personal Data relating to you to a third party (such as by checking a box to signify your agreement) we will transfer Personal Data to the relevant third party.
2.4. Disputes and Legal Advice. In case of any dispute or request with, by or concerning you, we may disclose Personal Data relating to you with our legal counsel, professional advisors and service providers, the relevant court or other tribunal and other third parties as needed in order to resolve the dispute, defend ourselves against any claims, or enforce our rights.
2.5. Mergers and Acquisitions. In the event that we, or a part of our business, are sold to a third party, or if we are merged with another entity, or in the event of bankruptcy or a similar event, we will transfer information about the relevant portions of our business as well as relevant customers and users and other personal data, to the purchaser or the entity with which we are merged. We may also transfer personal data to a potential acquirer, their legal counsel or service providers as part of an evaluation or due diligence review of our company in anticipation of an investment, acquisition or merger, though such transfers do not typically include personal data and are subject to obligations of confidentiality.
2.6. Affiliates. We share personal data with our affiliates, who assist us in processing personal data and providing our Services.
2.7. Additional information on our Service Providers (listed in Section 1).
To help you understand where data about you is transferred, here is more information about the service providers listed above whom we engage to process Personal Data that we collect. Where such service providers have made available information about their data security or processing practices which we think is relevant to you, we have provided links to such information. We take no responsibility for information found on their websites, including, without limitation, whether it is accurate or up-to-date.
- Amazon Web Services EMEA Sarl is a provider of cloud services, which we used to host the backend of our Services and store data that we collect. For more information about how Amazon Web Services handles data stored on behalf of its customers like us, visit https://aws.amazon.com/compliance/data-privacy-faq/.
- Apple, Inc., provides use with payment services (Apply Pay) which use to enable you to make payments within our Services. You can find out more about how Apple handles data you provide when using Apply Pay here: https://www.apple.com/legal/privacy/data/en/apple-pay/
- Atlassian, Inc., provides services for internal software development and maintenance, including a communications services used by software engineers or other personnel. Such communications may include Personal Data we have collected, though typically they do not. You can find out more about how Atlassian secures data it stores on behalf of its customers at https://www.atlassian.com/trust.
- Braze, Inc., is a provider of a customer engagement platform which we use to deliver messages to App Users (push notifications). You can find out more information about Braze at www.braze.com/.
- ElasticSearch Inc., provides us with a search and analytics engine capable we use to search and analyze data we collect. You can find out more information about Elastic at www.elastic.co.
- Facebook, Inc., provides us login features known as “Facebook Connect”. This allows us to receive information in connection with your Facebook profile in order to build a profile for you on the App. We also use a tool called “Facebook App Events” to track events and activity within the App. When you use the App, Facebook receives information about your use of the App. You can find out more about how Facebook uses Personal data at https://www.facebook.com/privacy/policy/
- Google LLC and its affiliates provide us with email and business suite (G Suite), cloud (Google Cloud), advertising (Google Ads) database (Firebase), analytics (BigQuery) and payment services (Google Pay). You can read more about Google’s policies in connection with data received from its customers at: https://privacy.google.com/businesses/compliance/.
- Innovecs, Ltd., is a software development company that assists in the development and support of our Services, and have access to our systems as part of performing services on our behalf.
- Mixpanel, Inc., is a provider of data analytics services, including “Mixpanel”. We engage Mixpanel to help us analyze and understand data we collect through our Services. You can visit Mixpanel’s website, www.mixpanel.com for more information about Mixpanel’s services.
- Oracle Corporation and its affiliates provide us with a relational database management service known as Mysql, that enables us to visualize, analyze, and use data we collect. For more information about how Oracle handles data we transfer to it visit https://www.oracle.com/legal/privacy/.
- Redis Labs, Inc., is a provider of a data structure store service which we engaged to organize and locate user data. You can find out more about Redis on their website, www.redislabs.com.
- Segment.io, Inc., provides a mobile attribution service which we use to organize information we collect and transfer it to the appropriate services we use. You can find out more about how Atlassian secures data it stores on behalf of its customers at https://segment.com/security/.
- Tableau Software, LLC, is a provider of a data visualization service known as “Tableau” which we use to analyze and understand the data we collect. You can find out more about Tableau on their website, www.tableau.com.
- Unity Technologies SF is a provider cross-platform game engine called “Unity” which we use to develop our games and deliver advertising to you when you play our games. More information about Unity’s data practices can be found at: https://unity3d.com/legal/privacy-policy.
4. Your GDPR Rights.
Subject to certain exceptions and exclusions, the following rights apply to individuals who are located in an EU member states or otherwise protected by the EU General Data Protection Regulation (“GDPR”), as further described below. If you are such a person, then:
- Right of Access. You may request that we confirm to you whether or not we store Personal Data about you and to receive a copy of the Personal Data we maintain about you and information about: (a) the purposes of the processing of the Personal Data; (b) the categories of Personal Data being processed; (c) the names of the recipients or the categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the Personal Data, or the criteria we use to determine that period; (e) the sources of the Personal Data, if not collected from you; and (f) whether we use automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
- Right to Rectify. You may request that we correct any Personal Data about you that we maintain that is incorrect. Depending on the purpose for which the data is used, you may also request to complete incomplete Personal Data we maintain.
- Right to Erasure (“Right to be Forgotten”). You may request that we erase or suppress Personal Data that relates to you in the following cases: the data is no longer needed by us; the data was collected and is used on the basis of your consent and you withdraw that consent; when you have a right to object to our use of the data (as described below under, “Right to Object”); we are not lawfully processing the data; or we are otherwise required by law to delete the data. However, there may be circumstances in which we may retain your data or we may refuse your request, for example, when we review the data to defend ourselves or make legal claims or exercise are own rights. In addition, this right may not apply to the display or access of your Personal Data outside of the European Union.
- Right to Restrict Processing. You may request that we restrict our use or processing of your Personal Data if: you claim the Personal Data is inaccurate, during the time we investigate your claim; our processing of the Personal Data was unlawful; we no longer require the Personal Data; we processed the Personal Data for our legitimate interests and you object to this use (as you are permitted to do under Article 21(1) of the GDPR), during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in which we are legally entitled to refuse your request.
- Right to Data Portability. You may request that we provide you with your Personal Data that we process based on your consent or to fulfill a contract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transfer your Personal Data to another entity or have us transfer it directly to such entity.
- Right to Object. You may, based on reasons specifically relating to you, object to our processing of your Personal Data, when: (i) the data is used for our legitimate interests and our interests in processing the data does not override your interests, rights and freedoms and we do not require use of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes or profiling for direct marketing purposes.
- Right to Object to Automated Decision Making. You may request that you not to be subject to a decision based solely on automated processing, including profiling, when the decision produces legal effects concerning you or significantly affects you.
- Right to Withdraw Consent. Where we process Personal Data relating to you based on your consent (such as by clicking a check box adjacent to a statement of consent), you may withdraw your consent and request that we cease using your Personal Data for the purpose for which you have your consent, or altogether, depending on the situation.
- Right to Make a Complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence, place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
You can exercise your rights that apply to us by contacting us by email at firstname.lastname@example.org. We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.
5. Transfers of Personal Data to other Countries outside the EU or EEA
We transfer Personal Data we receive in or from the European Union (and other locations) to the following countries outside the EU and European Economic Area. If Personal Data from the EU is transferred outside the EU to our affiliates or to third-party service providers, to countries which the European Commission has not determined to adequately protect Personal Data, we take steps to ensure that such Personal Data receives the same level of protection as if it remained within the EU. This includes entering into data transfer agreements and using the European Commission approved Standard Contractual Clauses.
- Israel, where we, and our services providers, Appsflyer, IronSource and Wix are located. As of the date of this Policy, the European Commission has determined that the State of Israel adequately protects Personal Data. (A list of countries which the European Commission has determined to adequately protect Personal Date can be found, as of the date of this Policy, here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
- The United States, where Amazon Web Services, Google, Facebook, Apple, MixPanel, Atlassian, Braze, ElasticSearch, Redis Labs, MySql, Segment, Oracle, and Tableau store information on our behalf.
- The Ukraine, where our software developer, Innovecs, is located and accesses our systems.
- If you are an individual protected by the GDPR, you may contact us in order to obtain additional information regarding the basis for the transfer of Personal Data relating to you to countries outside the European Economic Area. Please note that information or copies of documents we may provide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply with contractual obligations we may have (such as obligations of confidentiality).
6. Your California Privacy Rights
If you are a California resident you have the right under California law to make certain requests in connection with our use of Personal Data relating to you, as described below. To make such a request, please contact us by email at email@example.com. Please note that certain exceptions may apply.
6.1. Disclosure of Direct Marketing Practices (“Shine the Light”). Under California Civil Code Section 1798.83, one time per year you may request the following information regarding our disclosure of your Personal Data to third parties for their direct marketing purposes: a list of the categories of the personal information disclosed to such parties during the preceding calendar year, the names and addresses of such third parties, and if the nature of the parties’ businesses is not clear from their names, examples of the products or services marketed by such third parties. This right only applies if our relationship is primarily for your personal, family or household purposes and related to the purchase of our products and services.
6.2. Removal of Public Information of Minors. If you are under the age of 18 and have an account with us, under California Business and Professions Code Section 22581, you may request the removal of content or information you have publicly posted on our services that is identified with you or your account. Please be aware that certain exceptions may apply and we may not be able to completely remove all such information.
7. California Do Not Track Notice.
We do not track individuals’ online activities over time and across third-party web sites or online services (though we do receive information about the webpage you visited prior to access our websites, products and services such as our Site, the App, and advertisement landing pages. We do permit third-parties to track individuals’ online activities on our Site and App, this includes Google and Facebook which provide us with the analytics and tracking services described above. We do not respond to Web browser “do not track” signals or similar mechanisms. You can find out more information about do not track signals at: http://www.allaboutdnt.com/.
8. Third Party Websites, Services & Data Collection
Our Services may contain links to other websites, products or services offered by third parties (“Third Party Services”). This Policy does not apply to data collected by or on behalf of such third parties, whose privacy practices may differ from ours and who are not under our control. We are not responsible for the actions of such third parties or their data practices. Please review the privacy policies of any such third parties before you interact with them or provide them with Personal Data.
9. Personal Data of Children.
Our Services are not intended for, and we do not knowingly collect Personal Data from persons under the age of eighteen (18). If you believe that a person under the age of eighteen (18) has provided us with Personal Data, or if we have received the Personal Data of such person, please contact us at firstname.lastname@example.org.
10. Anonymous Information.
We do not treat information we collect or receive which is not or cannot reasonably be connected to any particular person or which is anonymized or aggregated such that it can no longer be connected to or used to identify any particular person as “Personal Data”, even if it was originally linked to or stored with Personal Data. Such anonymous information is not subject to this Policy and we may use it for a variety of purposes, may share it with third parties or even publish it for any reason.
11. Our Contact Information
For inquiries regarding this Policy, you may contact us as follows:
9 Sorek Street