Right Rocks
LIMITED (Right Rocks or "we", "us", "our") is a
technology company that designs and develops mobile games. With this Privacy
Policy, we aim to explain how and why we gather, store, share and use your
personal data in a manner consistent with the laws of the countries where we do
business.
Where this
Policy refers to "personal data" we mean any data or information that
identifies, relates to, describes, is capable of being associated with, or
could reasonably be linked, directly or indirectly, with a particular natural
person or household or any other data or information that constitutes
"personal data," or "personally identifiable information".
This Privacy
Policy applies to websites, mobile applications, forums, blogs, any offline
services, our marketing and advertising activities on all platforms and other
services that we may provide to you from time to time (collectively, the
"Services"). This Privacy Policy does not apply to our job applicants,
employees, or other personnel.
We are the
controller of the personal data we hold about you in connection with your use
of the Services. This means that we determine and are responsible for how your
personal data is used. Under this Privacy Policy, your personal data shall be
processed in order to provide the Services once you download our mobile
applications, access and/or play our games, or interact with our Services. If
you have any other concerns about providing data to us or it being used as
described in this Privacy Policy, you may contact us and use your rights
explained under Control Over Your Information section of this Privacy Policy.
We may
collect personal data directly from you or third-party companies who have obtained
your consent or have another legal right to share such personal data with us
(including advertising platforms, partners and data aggregators who have
obtained it). This may include attributes about you and your interests, as well
as other games and services you use, demographic and general location
information. We will use your personal data as described in this Privacy
Policy.
Personal Data
Collected Directly from You
We processes
your personal data in order to provide the Services when you download, access
and/or play our games or using our other Services. Most of this data comes
directly from you. We collect the following information you provide in
connection with our Services:
- Contact
Information, including your country or region, or username.
- User
Generated Content, including any files, documents, videos, images, data, or
information you choose to upload or transmit through your communications with
us or your use of the Services.
- Profile and
Gameplay Information, such as your screen name, avatar or profile picture; your
in-game scores, achievements and purchases; the competitions you enter and your
membership and participation in teams on the Services.
- Survey
Information, including feedback and ratings you provide relating to our
Services.
- Inferences,
such as information generated from your use of the Services, reflecting
predictions about your interests and preferences.
- Parental
Information, parent’s e-mail address and PIN to be created, only if you
activate parental control setting in the Services.
We use this
data to provide our games and Services to you, including optimizing our
Services, customization of in-game offers and verifying purchases. We may also
use it for the other purposes set out in this Privacy Policy.
Information
We Collect Automatically
Depending on
which of our Services you interact with, we may collect and process the
following types of information:
- Analytics
Data, including details about how you use and interact with our games,
advertising and other Services (for example, information about how and when you
use our Services, what device you use to access our Services or details
regarding profile visits, crash logs and diagnostic information (such as
battery life, loading time, latency, framerate, or other technical diagnostics)
about the performance of our Services on your device) and details regarding profile visits, resource download status, update
failure logs, and diagnostic information (such as battery life, loading time,
latency, framerate, or other technical diagnostics) about the performance of
our Services on your device;
- Device
Data, including your unique device ID (persistent/non-persistent), Identifier
For Advertisers (IDFA), Identifier for Vendor (IDFV), Apple/ Google game center ID, manufacturer, operating system,
CPU, RAM, browser type and language, current time;
- Location
Data, including your location based on your Internet Protocol ("IP");
- Commercial
Information, such as products and services purchased, obtained, or considered,
or other purchasing or consuming histories or tendencie (purchase ID, amount
spent, currency, date, time, vouchers or offers used);
- Data to
fight fraud (such as refund abuse in games or click fraud in advertising);
- Data from
platforms that the games run on (such as to verify payment);
- Data for
advertising and analytics purposes, so we can provide you a better Service.
- Technical and Operational Data: To provide you
with the most up-to-date content (such as new graphics, animations, and 3D
models) without requiring a full application reinstall, our Services may
automatically download additional resource files to your device. We collect
information about the status of these downloads and your device storage
capacity to ensure successful updates and optimal performance.
- Your email
address and your messages to the Services (such as chat logs sent by email or
any feedback you submitted about your experience with us; and/or other data you
choose to give us.
THIRD-PARTY DATA AND AUTHENTICATION:
Social
Media and Authentication Services
When you
interact with our Services through social networks or login services (such as
Sign in with Apple or Facebook), we may receive information permitted by those
networks, such as your name, profile picture, and user ID. If you use Sign in with
Apple, we will receive a unique user ID and, if permitted by you, the email
address associated with your Apple ID.
We and our
third-party providers may use (i) cookies or small data files that are stored
on an individual's computer and (ii) other related technologies, such as web
beacons, pixels, embedded scripts, location-identifying technologies and
logging technologies (collectively, "cookies") to provide our website
services. Please see the Cookies section of this Privacy Policy for the
detailed information.
Personal Data
Collected from Third Parties
As mentioned
above, most of the information that we collect about you comes directly from
you when you play our games or interact with our Services. However, when you
allow third-party companies access to your personal data (e.g., downloading our
mobile applications through App Store or Google Store and linking your Facebook
account to mobile applications), we also collect information from such third
parties.
- Social
Media:When you interact with our Services through various social media
networks, such as when someone "Likes" us on Facebook or follows us,
or shares our content on Google, Facebook, Twitter, or other social networks,
we may receive some information about individuals that they permit the social
network to share with third parties. The data we receive is dependent upon an
individual's privacy settings with the social network and may include name,
profile picture and friends list. Individuals should always review and, if
necessary, adjust their privacy settings on third-party websites, social media
networks, and services before sharing information and/or linking or connecting
them to other services. We use this information to operate, maintain, and
provide you with the features and functionality of the Services, as well as to
communicate directly with you, such as to send you emails about products and
services that may be of interest to you.
- Service
Providers: When you install or purchase items related to our mobile apps (such
as those you can purchase/download via App Store or Google Store),we does not
have access to your credit card or bank account data. However, third-party
payment processors stated above may share non-financial information with us
related to your purchases, like the items purchased to fulfill your order. The
personal data received from third-party companies will depend on privacy
settings on relevant third-party applications.
- Information
we receive from authentication services you connect to our Service:Some parts
of our Services may allow you to log in through a third-party social network or
authentication service such as Facebook. These services will authenticate your
identity and provide you the option to share certain personal data with us,
which could include your name, email address and user ID associated with the
third-party, profile picture, and the name and avatar of your Facebook friends
that are already playing our games.The data we receive is dependent on that
third party's policies and your privacy settings on that third-party site.
Where available, you will also be able to see which of your friends are playing
the same game and their progress through the games (and they will be able to
see you and your progress) or access other functionality we make available in our
games and other Services, such as inviting friends to play. You can choose not
to allow us to access your email address in the Facebook dialog box when the
first time you associate your Facebook account with your Right Rocks profile.
Logging in with Facebook will not allow us to post anything to your page
without your permission, and we will not receive any information about your
Facebook friends who do not play our games. If you do not wish your Facebook
friends to be able to see you and your progression in our games, you can
prevent this by disconnecting from Facebook from our games and updating your
app permissions from within your Facebook settings. If you choose not to create
a Right Rocks profile by connecting your Facebook account, the personal data
that we collect when you play our games will be linked to a random identifier
rather than information that could identify you directly, but we will collect
device-level identifiers and other information associated with those
identifiers described above. We recommend that you read Facebook's Privacy
Policy and review your privacy settings from time to time to ensure that you
understand fully how your Facebook data is shared.
- Other
Sources:We may also collect personal data about individuals that we do not
otherwise have from, for example, publicly available sources, third-party data
providers, brand partnerships, or through transactions such as mergers and
acquisitions. We use this information to operate, maintain, and provide you
with the features and functionality of our Services.
If you object
to us using your personal data for the above purposes, including direct
marketing, please let us know using the email address provided in Contact Us.
Where we use
your email to communicate marketing information to you we will seek your prior
consent where required to do so by law.
HOW LONG DO
WE KEEP YOUR PERSONAL DATA?
We will
process your personal data only for as long as is necessary for the purposes
for which it was collected in connection with the provision of service to you,
unless we have a legal right or obligation to retain the data for a longer
period, or the data is necessary for the establishment, exercise or defence of
legal claims.
We collect
and use your personal data for the following purposes:
- to enable
us to personalise your in-game profile, provide our games (including the social
elements of our games, such as team play and competitions), to ensure that your
purchases are activated in the games, and to provide you with player support if
you need it;
- to
enable us to optimize our games for you and for the device that you are using
(including the delivery and hot-patching of game assets such as images and
models), as well as to deliver customized in-game events, offers and
promotions;
- to manage
our organization and its day-to-day operations;
- to verify
your identity and entitlement to products or Services when you contact us or
access our Services;
- to request
your participation in our surveys about our organization, organizations we
partner with, and the Services;
- to help
maintain the safety, security and integrity of our property and Services,
technology assets and business;
- to operate,
improve and optimize our other games and other services;
- to
personalize our Services, understand our users and their preferences to enhance
user experience and enjoyment using our Services and improve our users'
experience;
- to provide
access to certain areas, functionalities and features of our Services, including
social features and multiplayer competitions;
- to
communicate with you regarding Services-related information, including
confirmations, technical notices, updates, security alerts and support and
administrative messages;
- to enable
players to communicate with each other in games or on our social media
accounts;
- to respond
to your comments and inquiries and provide customer support services;
- to prevent
potentially prohibited or illegal activities, including cheating or fraud and
to protect our players;
- to measure
interest in our Services;
- to ensure
internal quality control;
- to enable
us to comply with laws that apply to us, to prevent fraud, to ensure compliance
with our Terms of Service or, where necessary, to defend, exercise or establish
our legal rights, including our rights under our Terms of Service ;
- to ensure
the activation of parental control setting and verification;
- to comply
with contractual and legal obligations and requirements;
- to provide
support through our customer service channels when requested;
- to conduct
internal research and analytics; and as otherwise expressly set out in this
Privacy Policy or as required or permitted by law.
We may also
share, transmit, disclose, grant access to, make available, and provide
personal data with and to the following third parties. We disclose your
personal data for the purposes set forth in this Privacy Policy to provide the
Services to our third-party service providers, to comply with legal obligations,
and to protect and defend our rights and property.
- Other
Users: If you participate in any of our online communities or purchase goods or
services on our Services, we may disclose your public profile information to
other online community members, including your screen name, profile picture or
avatar, your in-game scores and achievements, as well as any other information
you choose to provide or make public.
- Contests,
Sweepstakes, and Survey Providers: We may share personal data with third
parties who assist us in delivering our contests, sweepstakes, or survey
offerings and processing the responses.
- Business
Partners: We enter into certain select marketing relationships with advertisers
and other companies that provide products or services that we believe may be of
interest to users of the Services. We may share personal data or any
information collected through the Services with those marketing partners in
order to help them send you information that we believe will be of interest to
you.
- Service
Providers. We may share your personal data with our service providers. The
types of service providers (data processors) to whom we entrust include
companies that provides (i) provision IT and related services; (ii) provision
of information and services you have requested; (iii) customer service
activities; (iv) analytics and search engine activities that assist us in the
improvement and optimization of the Services; and (v) any supporting activities
in connection with our Services.have executed appropriate contracts with the
service providers that prohibit them from using or sharing personal data except
as necessary to perform the contracted services on our behalf or to comply with
applicable legal requirements.
- Disclosures
to Protect Our Rights, Your Rights or the Rights of Others (e.g., as Required
by Law and Similar Disclosures): We may access, preserve, and disclose your
personal data, other account information and content if we believe doing so is
required or appropriate: (i) to comply with law enforcement or national
security requests and legal processes, such as a court order or subpoena; (ii)
to respond to your requests; (iii) to protect your, our or others' rights,
property or safety; (iv) to enforce our policies or contracts; (v) to collect amounts
owed to us; (vi) when we believe disclosure is necessary or appropriate to
prevent physical harm or financial loss or in connection with an investigation
or prosecution of suspected or actual illegal activity; or (vii) if we, in good
faith, believe that disclosure is otherwise necessary or advisable.
- Ad Networks
and Advertising Partners: We work with third-party ad networks and advertising
partners to deliver advertising and personalized content on our Services, on
other websites and services, and across other devices. These parties may
collect information directly from a browser or device when an individual visits
our Services through cookies or other data collection technologies. This
information is used to provide and inform targeted advertising, as well as to
provide advertising-related services such as reporting, attribution, analytics
and market research. Please see the Third-Party Data Collection and Online
Advertising section for more information.
- With Your
Consent: We may disclose personal data about an individual to certain other
third parties or publicly with their consent or direction. For example, with an
individual's consent or direction, we may post their testimonial on our Sites
or service-related publications.
- Sale of
Assets and Change of Control: If there is a sale of the assets of us or
corporate restructuring, or as a result of a change of control in the
shareholding structure of us, or in preparation for any of these events, any
third party to which we transfers or sells our assets will have the right to
continue to use the personal and other information that you provide to us in
the manner set out in this Privacy Policy.
Legal
Obligations and Rights: We may disclose personal data to third parties, such as
legal advisors and law enforcement:(i) in connection with the establishment,
exercise, or defense of legal claims; (ii) to comply with laws or to respond to
lawful requests and legal processes; (iii) to protect our rights and property
and the rights and property of others, including enforcing our agreements and
policies; (iv) to detect, suppress, or prevent fraud; (v) to protect the health
and safety of us and others; (vi) or as otherwise required by applicable law.
We participate
in interest-based advertising and use third-party advertising companies to
serve targeted advertisements based on your browsing history. We permit
third-party online advertising networks, social media companies and other
third-party services to collect information about your use of our online
services over time so that they may play or display ads on our Services, on
other websites or services you may use, and on other devices, you may use.
Our
advertising partners may help us serve ads to you by combining your personal
data with data they have collected about you elsewhere. They collect this
information when you use their services or the websites and services of third
parties. Our partners use this information to make assumptions about the kinds
of advertising you would prefer to see. If they determine that you would be
interested in seeing an advert for our Services, they will serve you with a our
advertising while using other websites and services. We use ad identifiers and
similar technologies to provide our Services to you and in order to collect
data from your device. These technologies allow our third-party advertising
partners and us to:
- recognize
you and your device;
- provide
interest-based advertising to you;
- allow our
Services to interact with a third-party social network or platform (where you
have chosen to allow such interaction);
- enable
third parties and us to provide you with more customized services, for example,
to provide our Services in the correct language.
Typically,
though not always, the information used for interest-based advertising is
collected through tracking technologies, such as cookies, web beacons, embedded
scripts, location-identifying technologies, and similar technology, which
recognize the device you are using and collect information, including click
stream information, browser type, time and date you visited the Sites, AdID,
precise location data and other information. We may share a common account
identifier (such as a hashed email address or user ID) with our third-party
advertising partners to help identify you across devices.
Our
third-party partners and we may use this information to make the advertisements
you see online more relevant to your interests and provide advertising-related
services such as reporting, attribution, analytics and market research. We may
also use services provided by third parties (such as social media platforms) to
serve targeted ads to you and others on such platforms. We may do this by
providing a hashed version of your email address or other information to the
platform provider.
Currently,
our website uses strictly necessary, functional, analytical/performance, and
advertising/targeting cookies. Please see the Cookies section of this Privacy
Policy for detailed information.
Like most
online services, our website uses the following types of cookies:
- Strictly
Necessary cookies. These cookies are essential for the proper functioning of
our website.
- Functional
cookies. These cookies enable a website to remember information that changes
the way the website behaves or looks, like your preferred language or the
region that you are in. The legal basis for our use of functionality cookies is
our legitimate interests, namely being able to maintain our website.
-
Analytical/performance cookies. These cookies allow us to recognize and count
the number of visitors to our website, to improve how our website works and to
see how visitors move around our website.
-
Advertising/targeting cookies. These cookies only work during your visit to our
website due to the presence of videos linked to third-party streaming
platforms. They are typically used to track the visitors’ online activity on
our website, and display more relevant advertisements.
Please note,
by playing our games, and unless you opt-out of interest-based advertising as
explained in this section, your personal data shall be used by our marketing
partners to collect and use information about you to improve advertising,
targeting and measurement systems as described in their privacy policies.
You can set
your web browser to warn you about attempts to place cookies on your computer
or limit the type of cookies you allow. Cookies used by our website operate
differently than browser cookies, and cookie management tools available in a
web browser may not remove cookies. Please be advised that if you disable
cookies, you may lose some of the features and functionality of our website
because the cookies are necessary to track and enhance your activities.
-Account Deletion and
Deactivation
Account
Deletion: You have the right to request the deletion of your account and all
associated data. In accordance with Apple’s requirements, you can initiate this
process directly within the 'Settings' menu of our game app by selecting 'Delete
Account'.
Deactivation:
You may also disassociate third-party accounts (like Facebook or Apple ID) and
delete the game from your device.
- Delete or
Reset our Services. There are other ways in which you can control the personal
data that we collect about you. For instance, delete our games from your mobile
device. You could also reset your mobile advertising identifier.
- Access to
Your Device Information. You may control the Services' access to your device
information through your "Settings" app on your device. For instance,
you can withdraw permission for the Services to access your network devices and
location data and to integrate with your other applications.
- Modifying
or Deleting Your Information. If you have any questions about reviewing,
modifying, or deleting your information, you can contact us by any method
described in the Contact Us section below. We may not be able to modify or
delete your information in all circumstances.
- Push
Notifications. We may occasionally send you push notifications through our
mobile applications with game updates, high scores and other notices that may
be of interest to you. You may at any time opt-out from receiving these types
of communications by changing the settings on your mobile device.
- Online
Advertising. If you prefer that your personal data is not processed to receive
interest-based ads, you can submit an opt-out request by contacting us
via info@right-rocks.com . You should note that if you opt-out of
receiving interest-based or targeted advertising, you will still see
advertising, and you may see advertising for our products and Services, but
that advertising will not be targeted using your personal data.
- Opting out
of interest-based advertising at a device level: You can choose to prevent your
device's ad identifier from being used for interest-based advertising, or you
can reset your device's ad identifier by changing your device's settings.
Settings vary from device to device, but you will usually find the ad
identifier settings under "privacy" or "ads" in your
device's settings.
- Cookies.
Please see the Cookies section of this Privacy Policy for the detailed
information on how you can control your cookie settings.
-Storage Permissions: Some Services may require
access to your device’s storage to download and save game assets
(e.g., textures and animations). You can manage these permissions through your
device settings, though disabling them may prevent the game from updating or
functioning correctly.
Being a user
of our Services, you may have certain rights in connection with your personal
data and how we handle it. In some circumstances, if the exercise of these
rights limits our ability to process personal data (such as in the case of a
deletion request), we may no longer be able to provide you with our products
and services or engage with you in the same manner. You may be able to exercise
these rights by contacting us at info@right-rocks.com
Those rights
include:
- Access to
personal data: You have the right to access your personal data that we use.
- Correction
or deletion of personal data: You have the right to ask us to correct or
complete your personal data if it is wrong or incomplete. You may also have the
right to ask us to delete your personal data when certain conditions apply.
- Account
deactivation: Should you wish to deactivate your account completely, you can
disassociate your Facebook account from our mobile games and delete 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 will be
lost, and we may not be able to restore them in the future.
- Restriction
on processing personal data: You may have the right to ask us to restrict the
use of your personal data when certain conditions apply.
- Object to
processing of personal data: You may have the right to object to the use of
your personal data by us when certain conditions apply.
- Portability
of personal data: You may have the right to receive your personal data in a
structured and commonly used format so you can use this data with another
company when certain conditions apply.
- Right to
opt out of: (i) Targeted advertising: You may have the right to direct us not
to process your personal data to provide targeted advertising. (ii) Certain
types of profiling: You may have the right to direct us not to process your
personal data for certain types of profiling activities. To use the right to
opt-out, you can contact us by any method described in the Contact Us section
below. Please also see the Control Over Your Information section of this
Privacy Policy for detailed information.
- Right to
non-discrimination. You may have the right not to receive discriminatory
treatment for exercising these rights. However, please note that if the
exercise of these rights limits our ability to process personal data (such as
in the case of a deletion request), we may no longer be able to provide you
with our products and services or engage with you in the same manner.
- Right to
appeal. If we decline to take action on a request exercising one of your rights
set forth above, you may have the right to appeal our decision.
- Right to
Withdraw Consent. There are certain circumstances where we require your consent
to process your personal data. In these instances, and if you have provided
consent, you may have the right to withdraw your consent. If you withdraw your
consent, this will not affect the lawfulness of our use of your personal data
before your withdrawal.
In certain
circumstances, we may decline a request to exercise the rights described above,
particularly where we cannot verify your identity or locate your information in
our systems. If we cannot comply with all or a portion of your request, we will
explain the reasons for declining to comply with the request.
We do not
intend to or knowingly collect personal data from children. We use the term
"children" to refer to someone who is (a) under 13 years old or, if
older (b) between 13 and 17 years old but under the age at which they can give
valid consent to the processing of their personal data under applicable local
or regional laws.
In general,
we do not intentionally or knowingly collect any personal data from children.
If a child under the age of 13 has provided personal data to us, we encourage
the child's parent or guardian to contact us to request that we remove the
personal data from our systems. If you believe that we might have any
information from or about children, please Contact Us. If you are an iOS user under the age of 13, your
data will not be tracked or collected for advertising purposes.
All personal
data collected or stored by us may be stored anywhere in the world, including,
but not limited to, the Republic of Singapore, the Republic of Indonesia. When
we transfer your personal data internationally, we will take reasonable steps
to ensure that it is treated securely, lawfully, and in the manner, we describe
here. Please note that laws vary from jurisdiction to jurisdiction, so the
privacy laws applicable to the places where your personal is transferred to or
stored, used or processed may be different from the privacy laws applicable to
the place where you are resident and may not provide the same level of
protection for personal data as the country from which it was transferred.
If you are
using our Services from the European Union or other regions with laws governing
data collection and use, please note that by providing your personal data to
us, you consent to process your personal data in the above-mentioned locations.
By choosing
to visit the Services or otherwise provide information to us, you agree that
any dispute over privacy or the terms contained in this Privacy Policy will be
governed by the laws of the Republic of Turkey and the adjudication of any
disputes arising in connection with our Services will be in accordance with the
terms of our Terms of Service .
The personal
data you provide to us is stored on servers located in secured facilities and
protected by protocols and procedures such as firewalls and data encryption
designed to ensure industry-standard security of such data. However, no server,
computer or communications network or system, or data transmission over the
internet can be guaranteed to be 100% secure. As a result, while we strives to
protect your personal data, we cannot ensure or warrant the security of any
personal data you transmit to us or through the Services.
By using the
Services or providing personal data to us, you agree that we may communicate
with you electronically regarding security, privacy, and administrative issues
related to your use of the Services. If we learn of a security system breach,
we may attempt to notify you electronically by posting a notice on the Services
or sending an email to you.
Our Services
may include links to third-party websites, plug-ins and applications. Except
where we post, link to or expressly adopt or refer to this Privacy Policy, this
Privacy Policy does not apply to, and we are not responsible for, any personal
data practices of third-party websites and online services or the practices of
other third parties. To learn about the personal data practices of third
parties, please visit their respective Privacy Policies.
We retain
your data for as long as your account is active or as needed to provide you
with the Services.
Note that if
you ask us to remove your personal data, we will retain your data as necessary
for our legitimate business interests, such as to comply with our legal
obligations, resolve disputes, and enforce our agreements.
We may update
this Privacy Policy from time to time, and we will post the updated Privacy
Policy on this page. When we make changes to this Privacy Policy, we will
change the date at the beginning of this Privacy Policy. If we make material
changes to this Privacy Policy, we will notify individuals by email to their
registered email address, by prominent posting on our Services, or through
other appropriate communication channels. Any new policy will be effective from
the date it is published by us.
For detailed
information collected under this Privacy Policy, you may contact us
here:info@right-rocks.com.