ONEGAME
PRIVACY NOTICE
Last updated: June 14,
2019
This Privacy Notice explains who we are, how
we collect, share and use personal information about you, and how you can
exercise your privacy rights. The Services are also governed by the Terms of Service.
We are OneGame Studio, maker of Cat Pop Island,
Tomcat Pop, Strike Galaxy Attack and many more. For details about how
to contact us, see the "How To Contact Us" section below.
This Privacy Notice applies to personal
information that we collect through our games, mobile applications and other
products ("Games").
1. WHAT PERSONAL INFORMATION DOES ONEGAME
COLLECT?
The personal information we may collect about
you through the Services falls into the following general categories:
1.1. Information that
you provide voluntarily
Certain parts of our Services may ask you to
provide personal information voluntarily. For example, we may ask for certain
information in order to register an account with us, to begin playing Games, to
subscribe to marketing communications from us, and/or to submit enquiries to
us, such as:
The personal information that you are asked to
provide, and the reasons why you are asked to provide it, will be explained to
you when we ask you to provide your personal information.
1.2 Information we
collect automatically
When you use our Services, we may also collect
certain information automatically from you and/or your device which may be
considered personal information under applicable data protection laws, such as:
�Advertising ID� means the Apple
Identifier for Advertisers (�IDFA�) on Apple, and Google Advertising Identity
(�GAID�). These are unique identifiers for mobile devices that advertisers use
for interest-based advertising. They are consistent across all apps and thus
allow cross-app tracking. On Apple, you can opt out by choosing the �limit ad
tracking� option in the privacy settings. On Google Android, you can opt out by
choosing the �Opt out of interest based ads.� Advertising IDs are
non-permanent, non-personal identifiers uniquely associated with your device.
Similar technologies include tracking pixels within ads. These technologies
allow companies (including marketers and advertisers) to recognize your device
when you use websites and applications.
�Device identifier / information� means device type, device model, device
manufacturer, device operating system and language, or other technical data
like screen size, processor, or a combination of this data, available from a
device for a developer to check the device�s compatibility with a particular
application.
Some of this information may be collected
using cookies and/or similar technologies (such as " software development
kits, or �SDKs�),
1.3 Information we obtain from third party sources
(a) Information from social media platforms.
You may choose to connect to our Services via your social media account. The
exact information we receive from you will depend on your social media privacy
settings, but it will typically include your basic public profile information,
such as:
Typical uses include updating game progress on
multiple devices you may own so that you can continue your progress using
multiple devices. In addition, we may show your Facebook friends in the Game
and show your public Facebook profile name and picture in Game leaderboards and
in your Game profile.
(b) Third party service providers. We may
receive personal information about you from third-party sources. We may get
your personal information, for example, when you installed our Game or when,
prior to installation, you click on an advertisement for the Game (see
"Third Parties" section below for further detail).
(c) Advertising partners. From time to time,
we may also receive personal information about you from other third-party
sources. For example, if you clicked on an advertisement directing you to one
of our Services (such as an ad for one of our Games in another publishers�
game), we will be provided with information about which ad network and
advertising campaign the install originated from (See also
"Advertising" below).
1.4 No special
categories of information
We do not request or intend to collect any
"special categories of information" such as any information on
health, race, religion, political opinions or philosophical beliefs, sexual
preferences or orientation.
2. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for the
following purposes:
2.1 To provide and
operate our Services:
2.2 To improve our
Services and keep them secure:
2.3 To personalize our
Services:
2.4 For promotional
activities (including marketing and advertising)
2.5 Other
3. ADVERTISING
3.1 We use advertising to fund our Services
and to make our games available for free. We show third-party advertising in
our Games and also advertise our Services via third parties. We want to provide
you with more detail about how we use information for advertising, both in our
properties and in third-party properties.
When you view ads in OneGame properties(e.g.
in our games)
3.2 To enable us to show in-game ads, we may
send your advertising ID and IP address to advertisers (or ad networks) to
enable them to find appropriate ads to serve to you in our Games and on
third-party properties. You can control and limit our use of your advertising
ID in your device settings. OneGame does not control which specific ads are
shown in our games (this is controlled by ad networks), but we do prohibit
certain types of ads.
3.3. Advertising IDs are used by ad networks
for a number of purposes (please refer to the Privacy Notices of our
advertising partners listed herein as "Third Parties") including, for
example, to:
(a) limit the number of times you see the same
ad
(b) ensure they are dealing with humans with
real devices and not automated �bots�
(c) to serve you with advertisements likely to
be relevant to you based on your advertising ID, your engagement with other
brands and ads which is recorded using your advertising ID, and to use your
general geographic area.
(d) Other brands buy ad placements via an ad
network or ad exchange to advertise their products in OneGame Games. The ad
network or ad exchange acts as intermediary between the other game companies
and OneGame. In order for an ad network to charge the company purchasing the
ad, clicks from the ad and potential installs of other developers� apps are
tracked. Views, clicks and installs from ads are measured using the Advertising
ID.
(e) Ad networks track which games you have
used to market you similar kind of games.
Your IP address is typically used by
advertisers to identify your general geographic location, for example, your
country, state and, sometimes, your city).
When you view OneGame ads on third-party
services
3.4 OneGame also advertises its games on other
apps by asking ad networks to place ads for audiences that will be interested
in them (determined using Advertising IDs).
3.5 Ad networks use Advertising IDs for this
and other purposes (please refer to the Privacy Notices of our advertising
partners listed as "Third Parties") including, for example, to:
(a) Measure ad effectiveness (looking at total
views, clicks and installs generated by its advertising in other publishers�
games);
(b) Inform players that have not played for a
while about new content in the Game. OneGame gives a list of these users in the
form of Advertising IDs to an ad network. The ad network then shows these users
ads about the new content.
(c) Not display ads for a game a player is
already playing. OneGame may send a list of active players in the form of
Advertising IDs to an ad network. The ad network then excludes these players
from seeing the ad.
(d) Market games to a group of potential
players. OneGame provides Facebook a list of Advertising IDs to match them with
similar type of Facebook users to whom OneGame could then market its games.
OneGame does not have information on how Facebook identifies or creates
profiles of similar type of users.
3.6 You can opt out of interest-based
advertising on mobile applications by changing the privacy settings of your
device and selecting "limit ad tracking" (Apple iOS) or "opt out
of interest-based ads" (Android).
4. COOKIES AND SIMILAR TRACKING TECHNOLOGY IN
WEBSITES
The Services may use �cookies� and other
technologies such as pixel tags, local shared objects, hardware-based device
identifiers, flash cookies, operating system-based identifiers, clear GIFs and
web beacons.
Cookies: A �cookie� is a small file your
browsers stores when told to do so by a website. Typically, websites place a
number of different cookies on an end-user�s device. Some are �First-party�
cookies,� i.e. from the website itself, and others are �Third-party� cookies,
meaning they belong to advertising and analytics entities or social networks.
Cookies are personal information. However, OneGame�s cookies do not include any
other personal information and are typically used to quickly identify your
device and to �remember� your device during subsequent visits for purposes of
functionality, preferences, and website performance. You can disable cookies on
your device or set your device to alert you when cookies are being sent to your
device; however, disabling cookies may affect your ability to use the Services.
5. LEGAL BASIS FOR PROCESSING PERSONAL
INFORMATION
Our legal basis for collecting and using the
personal information described above will depend on the personal information
concerned and the specific context in which we collect it.
However, we will normally collect personal
information from you only where (i) we need the personal information to perform
a contract with you, (ii) the processing is in our legitimate interests and not
superseded by your rights, or (iii) we have your consent to do so.
(a) Under our terms of service, �performance
of contract� as a legal basis for processing your information refers to when we
make the Game and Services available to you, provide customer support, integrate
Games with technology and distribution platforms such as Apple iOS and Google
Android, and inform you of service-related changes and Game progress.
(b) We process your personal data on the basis
of our legitimate interests for example when we provide you the Game and
Game events, serve interest based advertisements to you (both in-game and on
third-party properties), carry out marketing, keep our games secure, for
engineering purposes, analyzing the users� behavior across our Games,
moderating chat discussion.
(c) We have a �legal obligation� to process
your personal data when complying with a legal obligation, such as the
preventing a crime or fraud or maintaining tax records.
(d) If we ask you to provide personal
information to comply with a legal requirement or to perform a contract with
you, we will make this clear at the relevant time and advise you whether the
provision of your personal information is mandatory or not (as well as of the
possible consequences if you do not provide your personal information).
If you have questions about, or require,
further information concerning the legal basis for collecting and using your
personal information, please contact us using the contact information provided
in the "How
To Contact Us" section below.
6. WHO DOES ONEGAME SHARE MY PERSONAL
INFORMATION WITH?
We may share your personal information with
the following types of recipients:
(a) With companies in our business group,
third-party service providers and partners who provide data processing services
to us (for example, to support the delivery of, provide functionality on, or
help enhance the security of our Services), or parties that otherwise process
personal information for the purposes described in this Privacy Notice or
communicated to you when we collect your personal information.
(b) With any competent law enforcement body,
regulatory authority, government agency, court of law or other third party
where we believe disclosure is necessary (i) as a matter of applicable law or
regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to
protect your vital interests or those of any other person
(c) With a potential or actual buyer (and its
agents and advisers) in connection with any proposed or actual purchase, merger
or acquisition of any part of our business, provided that we inform the buyer
it must use your personal information solely for the purposes disclosed in this
Privacy Notice
(d) With any other person, with your consent
for such disclosure.
7. HOW DOES ONEGAME KEEP MY PERSONAL
INFORMATION SECURE?
We use appropriate technical and
organizational measures designed to protect the personal information that we
collect about you and process. The measures we adopt are designed to provide a
level of security appropriate for the degree of risk involved with processing
your personal information. Specific measures include encrypting your personal
information in transit and at rest.
8. INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred
to, and processed in, countries other than the country of which you are a
resident. These countries may have data protection laws that are different from
the laws of your country.
Specifically, our Game servers are currently
located in the United States, and our business group members, third-party
service providers and partners operate around the world. This means that when
we collect your personal information we may process it in any of these
countries. However, we ensure appropriate safeguards are in place so that your
personal information will remain protected in accordance with this Privacy
Notice. This includes complying with the European Commission�s Standard
Contractual Clauses for transfers of personal information among companies in
our business group and third-party service providers and partners, which
require all members of our business group to protect the personal information
they process from the EEA in accordance with European Union data protection
law. It also includes the transfer of personal information to third-party
service providers and partners that are certified under the EU-US Privacy
Shield.
The Standard Contractual Clauses can be
provided on request. We have implemented similar appropriate safeguards with
our third-party service providers, and partners and further details can be
provided upon request.
9. DATA RETENTION
We retain personal information we collect from
you where we have an ongoing legitimate business need to do so. For example, to
provide you with a Service you have requested, or to comply with applicable
legal, tax or accounting requirements. For example, we periodically de-identify
unused Game accounts and regularly review and de-identify unnecessary personal
information.
When we have no ongoing legitimate business
need to process your personal information, we will either delete or de-identify
it, or, if this is not possible � for example, because your personal
information has been stored on a backup server � then we will securely store
your personal information and isolate it from any further processing until
deletion is possible.
10. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
(a) To access, correct, update or request
deletion of your personal information. You may do so in your account settings
(via "Terms of Service and Privacy Notice") or by contacting
us using the information in the "How To Contact
Us" section below.
(b) To object to the processing of your
personal information (which is processed on the grounds of legitimate
interests), ask us to restrict processing of your personal information or
request portability of your personal information. Again, you may do so by
opting out of personalized offers based on in-game behavior, or by contacting
us using the information in the "How To Contact
Us"section below.
(c) To opt out of marketing communications we
send you, at any time.You can exercise this right by clicking on the �unsubscribe/opt
out� link in the marketing communications we send you or by contacting us using
the information in the "How To Contact Us" section below.
(d) If we are processing your personal
information with your consent, you can withdraw your consent at any time.
Withdrawing your consent will not affect the lawfulness of any processing we
conducted prior to your withdrawal, nor will it affect the processing of your
personal information conducted pursuant to lawful processing grounds other than
consent. You may do so by contacting us using the details at "How To Contact Us" heading below.
(e) You have the right to file a complaint
with a data protection authority about our collection and use of your personal
information. For more information, please contact your local data protection
authority.
You can control and limit the type of personal
information we collect and process about you in a number of ways. For example,
you can disconnect your social media account(s) from our games or control your
social media privacy settings to limit the information shared with us. You can
also reset your mobile advertising identifier or limit ad tracking altogether using
the settings on your phone. You can also limit or disable the use of cookies
(or similar technologies).
We will respond to all requests we receive
from individuals wishing to exercise their data protection rights in accordance
with applicable data protection laws.
11. AGE LIMIT
When we collect personal information we do not
know the age of our players. If a player has a Facebook account and has logged
into a game, we obtain the age information from the player�s Facebook profile.
If we discover we has inadvertently gathered personal information from a minor
under 13 years of age, we will take reasonable measures to promptly delete such
personal information from our records.
12. UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to
time in response to changing legal, technical or business developments. When we
update our Privacy Notice, we will take appropriate measures to inform you, in
accordance with the significance of the changes we make.
13. HOW TO CONTACT US
Data controller: OneGame Studio, Floor 4th - C'Land Building -
No 81 Le Duc Tho Street - My Dinh 2 Ward - Nam Tu Liem District - Hanoi City -
Vietnam. Email: khiemdb@mobiones.com.
You can exercise your right to access personal
information, request the deletion of personal information or opt out of
personalized offers directly in our Games.
To do so,
This is our preferred contact method, as we
can more accurately validate a request received directly from a device and
application.
Please note that other third parties (our data
partners) may be data controllers of your information.