1. About us and this policy
This policy describes how we and our other group companies (referred to collectively in this policy as ‘InnoFun’ or ‘we’, us’ and ‘our’) collect, use, process and share information that InnoFun collects about you. Our business is constantly evolving and so this document may change from time to time. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us.
This policy applies to all of our games, whether played on our website http://innofun.digital, on mobile devices, PC or on other platforms such as Facebook. It also applies to our advertising activities on all platforms as described below and other services that we may provide to you from time to time. In this policy we refer to our games, websites, advertising activities and other services collectively as our “Services”. Certain of our websites, such as our Investor Relations website, may have different privacy policies in relation to any information collected through those sites. The privacy policies applicable to those sites will be available on those sites.
For information collected under this policy, the data controller is INNOFUN DIGITAL ENTERTAINMENT LLC. INNOFUN DIGITAL ENTERTAINMENT LLC is registered with the U.S. Data Protection Commissioner. Other companies within the InnoFun group may also collect or have access to and use information about you for the purposes described in this policy.
As set out in the terms and conditions relating to our Services, you must be at least 13 years old to access and/or use our Services and at least 18 years old to access and/or use Royal Charm Slots. We do not knowingly collect personal data about children under the age of 13.
2. What types of information do we collect
We collect information from a number of different sources, but most of it comes directly from you when you play our games, or interact with our websites, advertising or other Services. Broadly the information we collect about you relates to the type of device you are using, how you play our games (such as levels attempted and purchases made), other games or apps you use on your device and may include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.
In more detail, depending on which of our Services you interact with we may collect and process the following types of information:
- details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our website(s), what device you use to access our games and services or details regarding profile visits, as set out in the section entitled “InnoFun Profile” in section 3, below);
- information that you provide us with when you fill in forms, answer questions or complete surveys when using any of our Services, when you create an account with us or if you invite your friends to use our games and Services;
- the content of messages sent using our chat and messaging systems;
- if you contact us, for instance through our InnoFun Care customer service channels, or respond to messages and communications that we send to you, we may keep a record of that correspondence;
- your interactions with us on our social media channels;
- information we collect via cookies and other similar technologies, as explained further below;
- information we collect from you when you connect our games or Services to third party platforms or social network services or use other social or player-to-player functionality; and
In some instances, when you make purchases on or through our website(s), we may collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by InnoFun. We do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful. When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play) we do not collect or store any payment information from you.
Finally, we may collect some of the information types referred to above on an aggregated or anonymised basis, or we may use it or share it in an aggregated or anonymised way, for research or analysis into the way our Services operate and are used.
3. Creating an InnoFun Profile and playing our games socially
When you play our games, we will give you a unique identifier which we will associate with an InnoFun account known as an “InnoFun Profile”. That InnoFun Profile will be specific to the InnoFun games played on an individual platform or device and will remain anonymous unless you choose to add your personal information to that InnoFun Profile. Others players in a game may be able to see your progress in the game and other information such as your game achievements, but no personally identifying information will be visible to other players. You can choose to add your personal information to your InnoFun Profile so that you can log in on multiple devices and synchronise your progress in our games across multiple devices on multiple platforms, and also so that you can play with your friends.
Your InnoFun Profile and the information it contains, such as your game achievements, will be visible to other users of our services. If you choose to add personal information to your InnoFun Profile it will be visible to your friends and other players anywhere in the world.
If you choose to view another individual’s profile, that individual and other users of our Services will know that you have visited them because some of your Social Data and a link to your InnoFun Profile will be displayed on that individual’s InnoFun Profile. They will also be able to visit your InnoFun Profile. You will also be able to see which other players have viewed your InnoFun Profile.
Connecting with third-party social networks
In the future we may also allow you to associate your InnoFun Profile with other social network accounts and use your log in details for that account to log into your InnoFun Profile. Where we do this, either we or your social network service provider will let you know what information we will receive about you from that social network.
If you choose to play our games online on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your InnoFun account. You can control how your Facebook information is used and shared with your Facebook friends in your Facebook account settings.
You can make changes to what data a third party social network or platform shares with us, or stop our Services interacting with that social network or platform by adjusting your settings with that third party provider, however you may find you are not able to enjoy all of the same features of our Services.
4. How do we use the information that we have about you?
We, our suppliers and group companies may use the information we collect about you for a number of purposes. These include providing our games and other services to you, optimising the games and services we provide, enabling in-app purchases, storing your progress through our games, enabling social network integration, providing customer service support when you need it. We also use your information in connection with our advertising purposes. For more information, see below. We may also use your information for research or analysis. Finally, there may also be other reasons why we need to use your information, such as maintaining records or protecting our legal rights. A more detailed description of how we use your information is set out below.
Providing and optimising our Services
We use your information to enable us to provide our games, websites, advertising and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our games work properly on all devices and are as enjoyable as they can be for all our players.
Some of our Services include player-to-player chat functionality. Users of our chat service(s) can send messages to other registered players. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history. We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.
Marketing and promotion
We may use your information to send you direct marketing and promotional materials relating to our Services or related products, for example sending you communications (including by email) for these purposes on our, or a third party’s behalf. For example, we might send you information about merchandise relating to our Services. If you do not want us to use your information in this way please let us know by contacting us at firstname.lastname@example.org.
We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and services. Finally, we will use your data to manage your account and relationship with us and improving your experience when you use our Services.
Analytics and Research
Social and Community
We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.
From time to time we may run competitions, including in games and via our community channels. Those competitions will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the competition.We may also publish the names and entries of competition entrants.
Cheating, crime and fraud prevention
We may use personal data that we hold to prevent cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police.
We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.
5. Advertising and promotion
What adverts you may see as a result of playing our games or using our Services
We promote our own games and services in a number of ways. That might include cross-promoting one of our games while you are playing a different game of ours. It might also include advertising our games within websites and other media published by others or sending you marketing materials by email.
Like many companies, we may use information about you in connection with advertising. This includes using information that we have about you, such as the games you play, to try to make sure you only see advertising that might be of interest to you. For example, if we know you play Candy Crush Saga, we might suggest that you continue the adventure in Candy Crush Soda Saga by showing you an ad for Candy Crush Soda Saga. We may also use the information that we have about you to help a third party deliver advertisements that are tailored to you based on a determination of your characteristics or interests by us based on the information that we have about you.
As well as advertisements for our own goods and services, we may also facilitate third parties to optimise their advertising of their own goods and services by helping them to target those ads to those that might be most interested in them. These advertisements may be shown within our games or within websites and other media which are published by others and optimised by us or using our information. This is done using anonymised information and we won’t hand over or sell any of your personal information to third party advertisers.
We will also use information about your particular device in order to show you adverts which work properly on that device, or to measure the effectiveness of our ad campaigns and we may also retain information about how many times you have seen a particular advertisement so we can stop you from seeing it too many times.
When we advertise our games in games or media published by other companies, we may use various third-party advertising partners, including ad exchanges, ad networks and ad servers.
Our advertising partners help us to serve advertisements to you. Some of this technology also helps us to make decisions as to whether or not to show a particular advert to you – for example, by informing us that you have shown an interest in similar goods or services previously.
How do ad identifiers, cookies and similar technologies work?
Advertisers on mobile devices sometimes use advertising (or ad) identifiers to enable and optimise their advertising. Ad identifiers are non-permanent, non-personal device identifiers such as the Android advertising ID and/or Apple’s ID for advertising, or IDFA. See below for you can reset these identifiers or indicate your preference that they should not be used for advertising purposes.
How to adjust your preferences
You can choose to prevent your device’s ad identifier being used for interest based advertising, or you can reset your device’s ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings.
You can disable cookies through your web or phone browser settings.
If you live in the USA, Europe or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).
Although we and our advertising partners use ad identifiers, cookies and similar technologies to enable us and third parties to provide more relevant advertising to you, these technologies also:
- allow us to recognise you and your device;
- allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
- allow our payment processors to process your payment instructions; and
- enable us and third parties to provide you with more customized services, for example to provide our services in the correct language.
As a result, if you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our services.
Please note that adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests.
Alternatively, if you do not wish us to collect data as described in this section, you should stop using our services.
6. Who else can see your information?
- as reasonably necessary in order to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfil the Services or to communicate with you);
- where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment processors);
- where your data is on an anonymous and aggregated basis, meaning you could not be personally identified from it;
- when you submit information as part of a competition or otherwise interact with our social media channels (for example, by providing a testimonial about one of our Services) we may publish the information you submitted, alongside your name and home country on our website(s) and social media channels;
- as we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of InnoFun, our users, or others;
Our games and our websites include social features that enable you to interact with other players. These features will enable other players to see your username, your avatar and your progress through our games and other game play related information such as high scores. Depending on your settings in your social network or InnoFun account, other information in your profile may be shared with other players. Also, other players will be able to see anything that you post to any public page, forum or other similarly open feature in our games, websites, community channels or other Services.
We may share your information with our service providers if necessary to enable them to provide services to us.
7. Your rights in relation to your information
You have certain rights in connection with your personal information and how we handle it. Details of those rights and how to exercise them are contained in this section.You have certain rights in relation to the personal information that we hold about you. Those rights include:
- Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information, and the law permits us to charge a fee for exercising this right of access. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 40 days of receipt of your request, evidence of ID and any applicable fee.
- Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know at email@example.com and we will correct it as soon as we can.
- Data deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please contact us using the information below. Please note that to ensure that we do not collect any further information you should also delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form.
- Account deactivation. If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, such as Gold Bars or Boosters will be lost and we may not be able to restore them in the future.
- Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
8. How long do we keep your information and where do we store it?
We will keep your information for as long as we consider necessary for the purposes described above, or as long as the law allows. We store your information on servers that we control which are primarily based in the European Union. We may also use servers that are located outside the European Union and we may engage partners outside the European Union who will also process and store your information to provide services to us.
9. Links to third party websites and services
10. Changes to the policy
11. Contact us