Effective Date: June 15, 2022
1. Identification of Data Controller.
2. The Information We Collect, How We Collect It, and the Legal Basis of it.
The legal basis for collecting and using the information depends on what the information is and the context in which We collect it.
Generally, We will normally process your personal information for a legitimate interest in efficiently fulfilling Our contractual and legal obligations, account management, management reporting, market review and analysis, promotion of Our Services, and business development. In some cases, the processing is necessary to perform Our contract with you (i.e., Our Terms of Service) or to fulfill legal obligations, or to protect your vital interests or those of another person (for example, another user).
Information You Provide To Us.
When you use Our Services, you may be asked to provide Us some or all of the following personal information:
Additional information may be requested for the purposes of securing your account and/or improving Our services.
Furthermore, We may also collect the following non-personal information:
We may also allow you to create a public profile, which other users of Our Services may be able to see. Your public profile may include the following information:
Information You Generate Using Our Services.
Additionally, when you use Our Services, We may collect information about the ways in which you use and interact with Our Services, such as when and for how long you play Our games, game features, and other players you interact with, purchase you make, progress or levels you achieve, and other gameplay activities.
If you contact Our Customer Support team, We may collect and store the contact information you provide (this may include, but is not limited to, your name and your email address, information about your gameplay or activity on Our Services, your game ID, username, operating system, and Unique Device Identifier (UDID)). We may also store the communications you have with Our Customer Support team and any additional information in those communications in order to provide ongoing support and improve Our Services.
Use of Social Media.
If you access any of Our Services through Social Media (for example, Facebook or Twitter), We may receive certain information about you. The information We receive is determined by each particular platform and the consent that you have provided to them.
Please note, third party social networks are governed by their own privacy policies, terms, and end-user agreements, and We are not responsible for and have no control over the sharing practices or policies of the third parties that operate those sites. For additional information, contact Us at firstname.lastname@example.org.
We do not receive any of your financial information. However, We may receive non-financial information related to your transactions within Our Services, for example, your name, your approximate physical location, and the item or service that you purchased.
The information that We receive is dependent on which Service you are using and which third-party provider manages the transaction.
Our Terms of Service explain Our policies regarding charges, billing, third-party credit, and virtual currencies. For more information, refer to our Terms of Service.
Cookies and Other Automated Information Collection.
3. How We Use Your Information.
We will use the information that you provide to Us for the specific purposes for which you provided that information, as stated at the time of collection. Hereunder are some of the ways in which We may use your information:
4. How We Share Your Information.
To Other Users.
As mentioned above, your public profile (such as profile photo, nickname, country, and game statistics) will be able to be seen by other users of Our Services.
To Third-Party Advertising, Including Behavioral Advertising and Analytics.
We may share some of your data, such as your advertising ID, with advertisers for the purpose of tailoring the advertisement you see when you use Our Services. We use advertising to be able to offer some of Our Services for free.
These advertisements may include, without limitation, video ads, banner ads, and ¡°offerwalls¡± in which third-party advertisers may provide virtual currency or other in-game items to users in exchange for completing a task.
The offers displayed within Our Services are created and hosted by third-party providers, not by GameSpring.
To enable advertisers, ad networks, and offer wall providers to serve you with more relevant ads, they may collect, or We may collect and share with them, the following types of information when you use Our Services:
In addition to serving you with relevant ads, the information collected may be used to:
After clicking on a third-party advertisement or offer, you may no longer be on a website/application/service hosted by Us. We are not responsible for the privacy practices or the content of those third-party services.
To Third-Party Service Providers.
GameSpring uses third-party companies to perform its services, like processing payments, analyzing data, optimizing gameplay, email delivery, hosting services, managing, and delivering contextual and tailored advertisements. We may share your information with third-party companies who perform services on Our behalf, like analytics, analysis, hosting services, customer service, marketing, and advertising optimization. We may also share your data with our third-party partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple, Google, Facebook, etc.). Where We share your data with third-party service providers and partners, We make every effort to ensure that there are appropriate agreements in place to protect your information.
About our Third-Party Data Controllers and Processors.
How Can You Turn Off Personalized Ads?
In addition, you can take the following steps to control the collection of your information:
If you are using an iOS device, you can find the official guide for opting out from Apple here.
Open the ¡°Settings¡± application of your Android device and select the ¡°Google¡± menu item. Depending on your device, this option may not be visible on the main menu, but you may use the search function at the top of the Settings menu to find it. From there, select the ¡°Ads¡± sub-item and activate the option ¡°Opt out of Ads Personalization¡± to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID on the same menu at any time (¡°Reset advertising ID¡±), and then a new ID will be created and will not be merged with the previously collected data.
Please note that if you reset your advertising ID or opt-out of interest-based advertising, you may still see advertisements in Our Services, but those ads will not be targeted based on the identifiers mentioned above. For example, such ads may be instead based on contexts, such as your progress and actions in Our Services, or your language preferences. Please be aware that such actions may result in a less enjoyable user experience.
5. How Long Do We Store Your Personal Information.
The period for which We will retain your personal information is dependent on the reason for which it has been collected. We will never retain your personal information for longer than is required to provide you with Our Services or to meet our legal obligations or to exercise, defend and protect Our rights, whichever is longest.
The personal information that associates you with an account and/or any of Our Services will be retained for at least as long as you have an active account with Us.
In the event you ask Us to delete or close your account, We will take all reasonable measures to delete your personal information from Our records. However, in the case that you have opted and agreed to submit optional content to Our Services, We may be unable to remove that content in its entirety. Additionally, We may retain select information where We need and have the right to do so, such as for legal and/or accounting purposes. Such cases may include but are not limited to, information related to your payments or customer service inquiries. We may also keep information in order to exercise, defend, or establish Our rights.
For more information on deleting or closing your account, please refer to article ¡°9. Your Rights¡±.
6. Security Measures for Your Information.
We implement all recommended industry practices in security measures to protect your personal information. We take all reasonable actions to prevent any unauthorized access or use of your personal information.
However, please be aware that regardless of any security measure used, We cannot and do not guarantee that hacking, data loss, unauthorized access, or any other type of breach will never occur. Any transmission of information is done at your own risk.
7. International Data Transfers.
GameSpring operates globally, and Our Services are global by nature. Your personal information collected via and/or by Us may be stored anywhere in the world and 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.
8. Policy Regarding Children.
The safety and privacy of children are of paramount importance to Us. Our Services are not intended for nor directed at users under the age of 17 (the ¡°Children¡±). We will never knowingly collect or solicit information from any Children. Children are prohibited from using any of Our Services.
Parents or guardians that believe that We do hold information about their Children should contact Us at email@example.com.
9. Your Rights.
Your rights include, but are not limited to:
To exercise any of your rights, please submit a request to firstname.lastname@example.org. You may be required to provide particular forms of proof of identity in order that We do not disclose personal data to those that are not entitled to it.
When you request the elimination of your personal information, We will only retain information that is subject to the terms described in Section ¡°5. How Long Do We Store Your Personal Information.¡±
11. Compliance with the General Data Protection Regulation (GDPR).
If you are a user using Our Services in the European Union or the European Economic Area, please read carefully the terms and conditions in this Section.
We strive for strict compliance with the applicable terms and conditions in the European Union¡¯s General Data Protection Regulation (hereinafter ¡°GDPR¡±).
Our definition of Personal Data (hereafter the ¡°Personal Data¡±) found in this section is in concordance to the definition contained in Article 4 of the GDPR. We will process your Personal Data in accordance with the applicable terms of the GDPR.
As set out in the GDPR, the requests you can make to Us can include:
Upon your request, We will promptly respond to your inquiry to the best of Our ability in accordance with the applicable provisions in the GDPR.
For more information about the personal data We process, or if you wish to exercise any of your rights, please send Us a request by email at email@example.com.
12. Notice to California Residents.
Collection and Use of Personal Information
When We use the term "personal information" in this Notice, We mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer.
In the last 12 months, We may have collected the following about consumers for the following purposes.
Category of Personal Data Collected
Personal Data Collected
Source of Personal Information
Categories of service providers to whom Personal Data was disclosed
Business Purpose for Collection
Name, username, email address, social media identifier, IP address, advertising ID, device and operating system information.
- Our players.
- Our player¡¯s devices.
- Social networks.
- Third parties.
- Customer services vendors.
- Advertising networks.
- Social media services.
- Data analytics vendors.
- Quality assurance vendors.
- Cloud storage providers.
- Service providers.
- App distribution platforms.
- Operate Our business and provide Our Services.
- Product development/improvement.
- Customer service.
- Detecting/Protecting against security events.
- Internal analytics and reporting.
- Internal research.
- Game mechanics or functionality.
- Facilitate player¡¯s social interaction.
- Maintaining and enhancing service, debugging.
- Advertising and direct marketing.
- Detecting/Protecting against security events, preventing fraud and abuse of Our policies.
- User acquisition.
- Compliance purpose and meeting legal/regulatory requirements.
Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code ¡× 1798.80(e))
Transaction information, purchase history. This does not include any payment information, which is collected directly by the mobile app distribution platform.
Protected classification characteristics
Internet or other electronic network activity information
Interaction with Our Services.
Inferences drawn from the above.
Please review Our partners' privacy policies to ensure that you understand their treatment of your personal data that they may process.
*Please note that We may not share your data with all of Our partners.
Selling Personal Information
Your California Privacy Rights
Your rights include, but are not limited to:
Right to know
You have the right to request any or all of the following information relating to the personal information We have collected about you or disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of personal information We have collected about you.
- The categories of personal information We have collected from you.
- The categories of sources from which the personal information is collected.
- Our business or commercial purpose for collecting personal information.
- The categories of third parties with whom We share personal information, if any.
Right to deletion
You have the right to request the deletion of personal information that We have collected from you, subject to certain exceptions.
Right to Non-Discrimination
You have the right not to receive a discriminatory treatment for exercising any of the rights described above.
However, please note that if the exercise of the rights described above limits Our ability to process personal information (such as in the case of a deletion request), We might no longer be able to provide you Our Services or engage with you in the same manner.
Right to designate an authorized agent to submit CCPA requests on your behalf
You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission, and the agent will need to submit to Us proof that they have been authorized by you.
The Right to Opt-Out of Personal Information Sales
You may be required to provide particular forms of proof of identity in order that We do not disclose personal data to those that are not entitled to it.
Note that GameSpring does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.
13. Contact Us.
For all other matters, please contact GameSpring through firstname.lastname@example.org or by physical mail to GAMESPRING CO., LTD., 23, Gangnam-daero 84-gil, Gangnam-gu, Seoul, Republic of Korea.