Your privacy is important to us, and we take our responsibility of caring for it seriously.  We respect your privacy rights and are committed to protecting the personal information that is collected about you. This Privacy Policy describes what information Spirit Apps collects and how we use, disclose transfer, and store it. If you do not want Spirit Apps to collect, store, use or share your information in the ways described in this Privacy Policy, you may not be able to play our games or use our services.

Spirit Apps , including its subsidiary companies (“Spirit Apps ”), collects, stores, and uses your information as a data controller in connection with, and in order to provide and develop, Spirit Apps games, mobile applications, services and websites (together referred to as the “Services”) in accordance with this privacy policy (“Privacy Policy”).

All of our Services, whether used on mobile devices, PCs or other platforms, are governed by this Privacy Policy. 

By using the Services, you hereby consent to this Privacy Policy.

This Privacy Policy is effective as of May 22, 2018 and was last modified on April 20, 2020.

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please see the “How to contact us” section below. 

1 – HOW WE COLLECT YOUR INFORMATION

Spirit Apps collects some information from you when you: (a) create an account, (b) play our games or use game-related services, (c) make a purchase within our Services, (d) create user-generated content, (e) watch advertisements within our Services, (f) sign up for a newsletter, (g) contact Spirit Apps customer service and take part in technical-support sessions, (h) enter a contest orparticipate in a challenge held by Spirit Apps , (i) chat with other users of the Services, (j) signal interest in participating in a playtest, (k) share or contribute to our social-media channels and other community websites, or (l) apply to a job.

2 – INFORMATION WE COLLECT

Spirit Apps collects only adequate and relevant information limited to the purposes defined hereunder.

a – Information you provide us

  • Contact information (such as your name and email address)
  • Your age
  • Your username and password
  • Profile information (such as a profile picture)
  • Information that you provide when seeking help from our customer service (such as chat logs and
  • customer-support tickets)
  • Other information you provide us (such as information used to identify a lost account)

b – Information we collect automatically directly from you when you use our Services

  • Information about your game progress and activity
  • Information about your interactions with other players
  • IP address and device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
  • Information about your device (such as device name and operating system, browser information, including browser type and the language you prefer)
  • Information we collect using cookies and similar technologies (Note: You can refer to our Cookies Policy to learn more about opting out of such technologies)
  • General geolocation information
  • Precise geolocation information (GPS)
  • Spirit Apps player ID

c – Information we obtain from our partners

  • Information that we receive if you decide to connect to a third-party social network (such as Facebook or Game Center)
  • Information from billing partners (if you subscribe to some games or make an in-game purchase)
  • Information for advertising and analytics purposes, so we can provide you with better Services

3 – HOW WE USE YOUR INFORMATION

We primarily use the information to provide you with a better gaming experience, but we also use your information, both individually and combined, as follows:

To operate our business and to enhance your gaming experience, including to:

  • provide you with the Services that are suitable to your age and compliant with the applicable laws of your country of residence
  • provide gaming experiences that you may like and functionalities you have subscribed to
  • track your use of the Services to help us learn more about your gaming activities and understand your preferences and tendencies, so that we can personalize your experience, provide you within-game offers and notifications that are tailored to you, and otherwise enhance your gaming experience
  • facilitate sharing on social networks
  • register your participation in a contest and contact you in case of prizes
  • offer you the opportunity to take part in playtesting (game tests)
  • protect against cheating, crime or fraud, or for other security reasons
  • identify and fix bugs and service errors
  • use it for administration, analytics, research, and optimization
  • compile statistics
  • comply with all regulatory and legal requirements, and answer any requests from Data Protection Authorities or any law-enforcement agency
  • To provide you with support, communicate with you and respond to any requests or questions you have submitted through our customer support.

To personalize our communication with you, including to: 

  • handle your subscription to, and opting-out of, our newsletters
  • contact you to promote our Services and contests we may offer
  • send you, with your prior consent, promotions or marketing materials (we will provide you with the opportunity to opt out of receiving such materials in the future)
  • provide you with advertising that better suits your interests and profile and is age-/gender-appropriate and targeted to your general location
  • serve and measure the effectiveness of advertising
  • collect any personal information you may disclose through messages you choose to send to another user or defined group of users through our message, chat, post or other in-game function, as well as to collect necessary personal information of the user(s) you are contacting, in order to facilitate the communication (Note: We will never collect any information sent outside of the functionality of our Services, including through emails or text messages)
  • personalize your content and offers
  • send you push notifications (if you choose to allow that function)—only for users 13 years old or older in the United States (16 or older in Europe)

For some purposes described above, Spirit Apps may use and perform analytics. Analytics information supports business analysis and operations, allows product development, improves products and Services, personalizes content, provides advertising, and makes recommendations. Our legal basis for collecting and processing your personal information (for European users) is described above.

We will normally collect personal information from you only:

  • when we have your consent to do so
  • when we need the personal information to fulfill a contract with you and provide you with the Services, such as customer services, bug and service-error detection, and fraud prevention
  • when the processing is in our legitimate interests (when we serve and measure the effectiveness of advertising or marketing campaigns, analyze your gaming activities, protect and improve our products and services) and not overridden by your rights, or
  • when we have a legal obligation to collect personal information from you

4 – HOW WE RETAIN YOUR INFORMATION

Spirit Apps retains, uses and stores your information as long as you are playing our games or using our Services, and also for the period necessary to fulfil all the purposes described in this Privacy Policy, in compliance with the applicable laws of your country of residence. We want to inform you that a longer retention period could be required to resolve disputes, or answer regulatory or police requests. In such cases, the collected information will be used and stored until the request is closed.

5 – HOW WE SHARE YOUR INFORMATION

With Spirit Apps entities In order to operate the Services, your personal information may be transferred to other Spirit Apps studios or entities, subsidiaries, processors or third parties located worldwide as described below (please refer to “International operations and transfers of your information”).

With third parties 

We use third-party services that have limited access to your information for specific purposes, such as administration, analytics, optimisation, advertising, prize delivery, marketing assistance, customer service, and data analysis. They assist us with our operations.

Such third parties are authorised to use your information for these purposes only.

If you decide, while using our Services, to use social sharing features such as “Share” or “Like” on Facebook or other third-party social network sites, this may allow the sharing and collection of personal and non-personal information both to and from such third-party social networks.

You should visit the policies of such third parties for more information about their information-collection practices.   Since Spirit Apps is part of the google Group, your information may be transferred to google entities for global projects. In that case, you will be informed of the nature of the relevant projects and the entities involved, and you will be asked for your prior consent before any transfer of your information takes place.

With authorities 

We reserve the right to report to law enforcement agencies activities that we, in good faith, believe to be illegal. We will investigate or take action to counter illegal activity, suspected abuse or unauthorised use of the Services, or to protect the property or safety of others. We also may disclose your information if required by any law or court order worldwide, if the information relates to actual or threatened harmful conduct.  In that case, we will consider applicable local laws, the nature of the order, as well as the legitimacy and proportionality of your information.