Last Updated: May 9, 2017
COLLECTION OF DEVICE AND TECHNICAL INFORMATION
We collect the data necessary for you to use our app, personalize its content during your use, and for us to maintain, analyze and improve its functionality.
We automatically obtain certain information about your computing device, including:
IP address; Country code;
IDFAs, IDFVs, Advertising IDs;
Language; Locale (specific location where a given language is spoken);
Time zone, session start/stop time,
Network status (WiFi, etc.), browser plug-in types and versions;
User agent string (UA), platform, SDK version, timestamp;
SapientX Applications installed;
Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, International Mobile Equipment Identity (IMEI) on Android, Android Serial No);
Push notifications token;
Player identifier string (we collect player identifier string only upon your sign in to Google Play Games Services or Apple’s Game Center).
In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Applications.
Although some of this information (such as IDFA, IDFV, Advertising ID, IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as in the United States) may treat information that uniquely identifies your device as personal information.
COLLECTION OF APPLICATION USAGE INFORMATION
When you use the Application or the Website, we may collect additional information by using device identifiers in a form that does permit identification of your device. The information collected includes:
Angle of view;
Heart rate monitoring;
Gyroscope and GPS information;
Application usage information, including in-game location;
Website usage information; and
Characteristics obtained by your use, such as data about pages of our Websites or Applications that were viewed during your visit, any actions or movements within the Websites or Applications and movements to/from the website from/to another website, date and time, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
COLLECTION OF CLASSICAL PERSONAL INFORMATION
We may also collect personally identifiable information about you (such as your name and surname, email address), as well as non-personally identifiable information (such as age range, year of birth and gender: this information is collected only for users who have already identified themselves as above the age of 13) that you provide us, by using our Application, when you voluntarily register with SapientX, request information using the Website, or contact us directly.
We will only use the contact information you provide to us (for example, your name and email address) for the purpose for which you provided it to us. We will not share this data with third parties.
If you wish to delete your contact information that we received upon your specific inquiry, please send an e-mail to support@SapientX.com and your contact information will be deleted from our database.
For the SapientX App we also collect the information about the name you give to the avatar, your rating of the Application (if any) and for the nickname you choose. Please do not use your real name.
SHARING OF INFORMATION UPON YOUR REQUEST
We access your social network profile if you allow us to for the purposes of using in-game features.
We may access and store some or all of the following information, as allowed by you, Third Party Social Networks and your preferences: (i) your basic information from your profile, such as your name, surname, email address, login ID, preferences, player identifier string; (ii) your photos and videos. The Application may further ask you to allow us to (i) post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates) and to (ii) manage your notifications (access your notifications and mark them as read). Please keep in mind that we will only do that if specifically directed by you and we will store your ID and your full name only for the purposes of user identification. Other information will be merely stored within the Application on your device so that the Application will be able to communicate with Third Party Social Network directly; Voice recordings from Applications are also only being collected and stored within the Applications upon your request.
CONSENT TO PUBLIC DISPLAY OF DATA UPON YOUR ACCEPTANCE
We may publicly display your data when you participate in game related activities for the purposes of user identification.
PRIVACY SPECIFICS OF CERTAIN APPLICATIONS
For the SapientX App we might ask you for your age, provided that this data shall be visible to us only to us on an aggregated level. This means that the age you provide shall not be seen in your data log, but it will be hashed in the app; we will not be able to connect it with your specific device ID. The age information provided shall be used only for making the Application more appealing to users.
We are collecting statistical data about the gameplay. Such data includes, for example: how you use the in-app functionalities, such as how long you play with the Application; what sort of questions you ask; how you navigate through the Application; the time and duration of your use of the Application; and what your estimated sentiment is.
OUR USE OF INFORMATION
We use the information we collect from you for delivering and promoting our services, internal analysis and research to improve the services and to display advertisements.
We use the information we collect about you/your computing device to deliver services to you and to operate our business. Such use by us and by our Partners may include:
Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analyzing trends in connection with usage of the Applications and the Websites, administering the Applications and the Websites, and customer communications. For information that can be treated as personal information in some legislation, we use only device identifiers.
Tracking for advertising purposes: For some Applications we may track installs through our tracking providers for the purposes of measuring our advertising campaign performance.
We will only use push notifications to remind you about your activities within the Application. You will receive push notifications only if you are subscribed to push notifications in the Application. To unsubscribe, please use the instructions provided below:
For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap “Notifications”; Find the Application; Tap on the icon of Application; Manage the “Notifications” option by sliding it OFF or ON.
For Android and Windows: After an Application is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the Application and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the Application.
We collect push notification tokens in order for us to be able to determine whether you are subscribed to push notifications. When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.
We are conducting surveys in order to improve our services and you may freely decide whether you would like to help us or not.
From time to time we may conduct an e-mail and/or an in-app survey and collect demographic and usage information for the purposes of internal analysis, marketing and brand development. Participating in a survey is completely voluntary. We will use the information to make our services more appealing to users. Collected information shall be anonymized and aggregated. We might collect the following information: age and gender of the user of an app, whether another person uses the app, the age and gender of the people regularly using the app, assessment of popularity of the main character, which of the characters are known to the user, which app is most commonly used, whether children under the age of 13 use the app on their own or with an adult, the gender of users playing the app, different ways of using the app, an assessment of the features of an app, the time period of using the app, which apps the user has, what would make the app more appealing, and other information needed for the purposes of internal analysis, marketing and brand development.
We may use third party providers for the in-app surveys and they may place their tags within an Application to collect non-personally identifiable data from the device (”Tag Data”) solely for the purposes of conducting the survey, such as to collect cross device information in order to enable the deduplication of audiences across devices. These providers may use the data collected from the survey and Tag Data on anonymized and aggregated basis together with the data from other partners (”Unified Data”) to publish syndicated reports on internet behavior and trends. If you do not wish to receive promotional, marketing or research materials please send an e-mail to email@example.com and your e-mail will be excluded from our user database. If you do so you will no longer receive special and discount offers from us. If you wish to opt out from conducting an in-app survey, do not click on the survey button or deny answering the survey questions.
TRANSFER AND STORING OF INFORMATION
We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need them for providing our services.
For European Union Countries
For the United States
Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our services.
DELETION OF INFORMATION
When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.
DISCLOSURE TO THIRD PARTIES
We disclose the information to our advertising and analytics partners so that we can display advertisements and analyze the usage.
We cannot provide all services necessary for the successful operation of the Applications or the Website by ourselves. We must therefore share collected information with third parties, including analytics providers, tracking providers, third party advertising providers and other third party service providers that support the Applications and the Website (collectively referred to as “Partners”). We may share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of delivering our services, displaying advertisements, conducting analysis and research and for measuring our advertising campaign performance:
Third party analytics providers: For some Applications we use third party analytics such as Google Analytics (for Applications), Google Analytics (for Websites) and Firebase Analytics for the purposes of delivering our services, conducting analysis and research. To get more information about how your data is being collected and processed you can visit the site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. Additionally we have also integrated Google Play Developer Console data like Impressions, Downloads, and Traffic Sources into a Google Analytics account to see how many times people viewed or downloaded our apps from Google Play. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. Third party analytics providers have the right to process the data in accordance with their privacy policies and such collection and processing is limited to the disclosure in aggregated manner, for the purposes of showing trends about the use of their services, for advertising services and marketing purposes. We can aggregate the data for benchmarking feature.
Third party tracking providers: For some Applications we may track installs through our tracking providers such as Adjust and AppsFlyer for the purposes of measuring our advertising campaign performance. The tracking providers may use and share the information so gathered, but only in aggregated and anonymized manner.
Third party advertising providers: The Applications may incorporate third-party dynamic in-game advertisement serving technology which enables advertising to be temporarily uploaded into the Application. When you use the Application, we or third parties operating the advertisement serving technology may use information logged from your device using cookies, web beacons and other technologies to ensure that appropriate advertising is presented within the Application and to calculate the number of unique and repeat views of advertising. We have contracted with certain third party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Applications for free or at low cost. Such third party advertising providers include but are not limited to advertising providers listed at https://SapientX.com/third-party-ad-providers/.
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Applications or the Website. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.
We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.
USE OF INFORMATION BY OUR PARTNERS
We strive to commit our Partners to using the information solely for the purposes as stated above. If they use information that might be considered as personal information, they should use it solely for the purposes of contextual advertising, but for any other purposes they should use the information solely on anonymized and aggregated basis. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices. While we strive to protect the information provided to our Partners, we have no direct control over their use of the collected information and therefore you acknowledge that we are not liable for any third party privacy breach and that our liability for our Partner breaches is limited to the amount we are able to receive as indemnification from our Partners (legal costs exempted).
In addition, Partners may use their own tracking technologies (including and without limitation: cookies, Web beacons, HTTP cache, and local shared objects) to compile anonymous information about users of the Applications and visitors to the Websites. Partners may share anonymous information that they collect with their clients, including the date and time a banner ad was shown and the specific ad shown. We strive to ensure that this information is only disclosed to such third parties in an anonymized and aggregated manner.
Some of the Applications allow you to submit content generated in or by the Applications to third party sites like Facebook, Vkontakte, Google Play Games, Game Center and YouTube. These submissions follow the information transfer protocols for such third parties, which are designed to enable content sharing with such third parties.
THIRD PARTY TERMS AND CONDITIONS
Please note that your access to and ability to use and interact with the Applications and the Websites may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, online gaming platforms, social networking services, statistics services providers and payment providers. You recognize and agree that SapientX is not liable for any such third party terms and conditions and their use of your personal information.
PROTECTION OF PERSONAL INFORMATION
INTEGRITY OF PERSONAL INFORMATION
We strive to enable you to keep your information accurate, complete and up to date. You can access, check and ensure the integrity of your information as described below.
ACCESS TO PERSONAL INFORMATION
Access, correction or deletion requests regarding your personal information may be submitted to support@SapientX.com.
We make good faith efforts to provide you with access to the personal information you provide to us (information associated with your account). You can also request that we correct or delete information, provided that we are not required to retain such information by law or for legitimate business purposes.
We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction or deletion requests can be made by contacting support@SapientX.com. For some of our Applications we may develop in-app deletion request functionality which can be used in addition to the address above.
INFORMATION COLLECTION RELATING TO CHILDREN
We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed to, and we do not knowingly collect personal information from, children under 13. If we learn that we have collected personal information of a child under 13, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at support@SapientX.com.
In order to preserve the family-friendly reputation of our Applications, we age-gated some of the features in our applications, so that they are not available for use by children under 13. The age gate is being conducted after the download of some of our apps for specific territories in order to assure the privacy and protection of younger users of our apps. If you do not pass the gate the features enabling potential collection and sharing of personally identifiable information are disabled for your device ID. For your safety, it is not possible to change your age later on. We do not store your year of birth but only the information whether your device ID passed the age gate or not.
The only personal information we collect from you for the purposes of offering our services are persistent identifiers (such as device ID, IDFA, IDFV, advertising ID, IP address). Such persistent identifiers are used and shared with third parties solely for providing support for the internal operations meaning to place contextual advertisement (including frequency capping), to authenticate users of or personalize the content on Applications, to maintain or analyze the functioning of the Applications, personalize the content of the Application (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the Application, to ensure legal or regulatory compliance.
If you have questions or concerns about our privacy practices, please contact us at support@SapientX.com.
THIRD PARTY SITES
Our Applications, Websites, products and services may contain links to third party websites, products, or services. For example, the Applications may feature offers from third party advertisers or the ability to engage in transactions with such entities. Please note that while using such third party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We are not responsible for the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party’s privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. These other websites or services may place their own cookies or other files on your computing device, collect information or solicit personal information from you. We encourage you to learn about the privacy practices of third parties with which you interact.
We are not responsible or liable for your interaction with such third parties, the information requests initiated by such third parties, or the subsequent use, treatment or dissemination of information you voluntarily choose to provide to them.
Our Applications enable in-app purchases.
Although some of our Applications are free, they include in-app purchases. In-app purchases may be made only upon entering the app store password and you are responsible for maintaining the security of such password. Your authentication and security maintaining is subject to specific terms of the app store and the OS of your mobile device. You should be aware of the iOS’ 15-minute and Android’s 30-minute window after the downloading of an Application, during which in-app purchases may be made without inserting an in-app store password. You should also take into account that OS 2.1 or older versions of Android mobile phones do not require entering of the app store account password to carry out in-app purchases.
Your iOS or Android mobile device may provide a “Limit Ad Tracking” or “Opt Out of Interest-Based Advertising” setting. When you have opted out using this setting on a device, our partners will not use information collected from that device to infer your interests, or to serve ads to that device that are targeted based on your inferred interests.
OPTING OUT FROM FIREBASE ANALYTICS
Our apps may use Firebase Analytics. To get more information about how your data is being collected and processed you can visit the site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. We have created an opt-out option within our apps that use Firebase Analytics. Should you decide to opt out, you may do so by visiting ”Info Screen”, ”Settings” and ticking the ”Opt Out of Analytics” button.
Any questions? Send us an e-mail to support@SapientX.com.